Today is the fifth anniversary of the Dodd-Frank Act and it’s the CFPB’s fourth birthday. Do you feel like celebrating? The Dodd-Frank Act continues to stir up controversy and is likely to be a topic of much discussion during the upcoming presidential campaigns. By one estimate only 60% of the total Dodd-Frank rules have been completed; the rest will continue to unfold in the coming years. The Dodd-Frank Act spawned the Consumer Financial Protection Bureau. […]
Category: Dodd-Frank Act
FINAL RISK RETENTION RULES
On October 22, 2014 the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission jointly issued a final rule to implement the credit risk retention requirements of section 15G of the Securities Exchange Act of 1934 (15. U.S.C. 78o-11), as added by section 941 of […]
PROPOSED REPEAL OF REGULATION AA
On August 22, 2014 the Federal Reserve Board requested comment on a proposal to repeal its Regulation AA (Unfair or Deceptive Acts or Practices). Also on Friday, the Board, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency issued guidance clarifying that the repeal of the credit practices rules applicable to banks, savings associations, and federal credit unions is not a determination that the […]
ATR/QM POLL
Recently we polled our Compliance Master Group members on the Ability-to-Repay/Qualified Mortgages rules. There were no huge surprises, but we got a lot of confirmation of what we expected to see: Most creditors use a mix of ATR/QM options; The Small Creditor QM is the most popular ATR/QM option; Adopting the ATR/QM rules was a challenge, but did not reduce loan volume for most creditors; and Most creditors have not yet adopted Appendix Q, but […]
HMDA PROPOSAL PUBLISHED
On July 24, 2104 the Consumer Financial Protection Bureau (CFPB) published proposed rules to implement changes to the Home Mortgage Disclosure Act (HMDA). Some of the proposed changes are mandated by the Dodd-Frank Act, others are part of a CFPB effort to modernize and streamline regulations. Comments on the 572-page proposal are due on or before October 22, 2014. Coverage There had been speculation that coverage would be expanded to all mortgage lenders that originated […]