On December 11, 2013 the Department of Housing and Urban Development (HUD) published a final rule to establish a definition of “qualified mortgage” (QM) for the single family residential loans that HUD insures, guarantees, or administers that aligns with the statutory ability-to-repay criteria of the Truth-in-Lending Act (TILA) and the regulatory criteria of the definition of QM promulgated by the Consumer Financial Protection Bureau (CFPB). The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank […]
Category: Dodd-Frank Act
NEW INTEGRATED DISCLOSURES RELEASED
On October 20, 2013 the Consumer Financial Protection Bureau published the new rules for the integrated disclosures. The new rule is 1,888 pages long and is effective on August 1, 2015. The CFPB is not revising finance charge rules at this time. A copy of the new rule is available here.
KNOW BEFORE YOU OWE: MORTGAGES
As we recently reported, today is a big day for mortgage lenders. The Consumer Financial Protection Bureau (CFPB) is releasing the new integrated disclosures in conjunction with a field meeting scheduled at 11:00 a.m. in Boston. The new Loan Estimate form combines the good faith estimate and the early TIL disclosure. The new Closing disclosure combines the HUD-1 and the final TIL disclosure. The good news is that use of the new forms will not […]
HOMEOWNERSHIP COUNSELING ORGANIZATIONS LISTS
Section 1024.20(a)(1) of Regulation X requires lenders to provide the loan applicant with a written list of homeownership counseling organizations that provide relevant services in the loan applicant’s location. The rule is effective on January 10, 2014. On November 7, 2013 the Consumer Financial Protection Bureau (CFPB) issued a final rule and made available a tool that produces the appropriate list of counselors. A lender may use the CFPB tool or may develop its own […]
ESCROW EXEMPTION WINDOW REMAINS OPEN
Some creditors never wanted to play the escrow game. Section 1026.35(b)(2(iii) of Regulation Z creates an exemption from escrowing on first-lien higher-priced mortgage loans for certain creditors. The exemption originally required action by June 30, 2013. Some creditors that were eligible for the exemption missed the June 30th deadline and the opportunity for the exemption. A subsequent revision to Regulation Z has reopened the window of opportunity for taking advantage of the exemption until January […]