On August 28 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 issued a notice revising a proposed rule requiring sponsors of securitization transactions to retain risk in those transactions. The new proposal revises a proposed rule the agencies issued in 2011 to implement […]
Category: Financial Reform
CRIMINAL BACKGROUND CHECKS AND CREDIT REPORTS FOR LOAN ORIGINATORS
I have had a lot of questions regarding new loan originator qualification standards that take effect on January 10, 2014. On January 20, 2013 the Consumer Financial Protection Bureau (CFPB) published revisions to Regulation Z that expand the SAFE Act requirements that apply to Loan Originators. It is odd that SAFE Act revisions end up in the Truth in Lending Act, but this not the most seriously odd thing that Congress has done lately. Section […]
CFPB PUBLISHES PRELIMINARY LIST OF RURAL AND UNDERSERVED COUNTIES
On March 12, 2013 the Consumer Financial Protection Bureau (CFPB) announced the availability of a preliminary list of rural and underserved counties. The final list will be available before June 1, 2013. The list has significant impact on several regulatory requirements, as follows: On June 1, 2013, the CFPB’s Escrow Requirements under the Truth in Lending Act rule (Escrows Rule) will go into effect, which require certain creditors to create escrow accounts for a minimum of 5 […]
APPEALS COURT DECISION CREATES TURMOIL
In the past few weeks the Consumer Financial Protection Bureau (CFPB) put in place over 3,500 pages of new regulations to implement various provisions of the Dodd-Frank Act. Or, maybe they didn’t. Yesterday the D.C. Circuit of the Federal Court of Appeals issued a ruling that the President can make recess appointments only when the Senate has formally adjourned between sessions of Congress. If the ruling stands, various appointments, including President Obama’s recess appointment of […]
FINAL LOAN ORIGINATOR COMPENSATION RULES NOW AVAILABLE
On Sunday January 20, 2013 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation Z to revise and clarify existing regulations and commentary on loan originator compensation. The rules also implement Dodd-Frank Act provisions that prohibit certain arbitration agreements and the financing of certain credit insurance in connection with a mortgage loan. The 540-page final rule was published just hours before the Dodd-Frank mandated January 21, 2013 deadline. The rules take effect […]