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CFPB PUBLISHES FINAL RULES FOR HIGH-COST MORTGAGES AND HOMEOWNERSHIP COUNSELING

Today the Consumer Financial Protection Bureau (CFPB) published a 431-page final rule to strengthen consumer protections for high-cost mortgages and to provide consumers with information about homeownership counseling. The rule is effective on January 10, 2014. The final rule amends: Regulation Z (Truth in Lending) by expanding the types of mortgage loans that are subject to the protections of the Home Ownership and Equity Protections Act of 1994 (HOEPA), revising and expanding the tests for […]

ABILITY TO REPAY RULES TO BE PUBLISHED TODAY

The Consumer Financial Protection Bureau (CFPB) will publish the long-anticipated amendments to Regulation Z to implement the ability to repay rules today. The rule will be effective next year. CFPB Director Richard Cordray will officially announce the new rule in an event scheduled for later today in Baltimore. The is the first of several final rules scheduled to be published by the end of next week. The rule imposes a range of obligations and restrictions […]

MORE ON TESTING INTEGRATED MORTGAGE LOAN DISCLOSURES

Following our recent article about testing the integrated mortgage disclosure forms we received several inquiries requesting more information about the process, particularly about submitting a comment. This article responds to those requests. The Issue – The volume of changes from the Dodd-Frank Act that are currently unfolding is daunting. Over 2,400 pages of proposed regulations have been published in just the past two months alone. A huge bank can assign a team to the task of […]

YOUR ASSIGNMENT: TEST INTEGRATED MORTGAGE LOAN DISCLOSURES

The volume of changes from the Dodd-Frank Act that are currently unfolding is daunting. Based on the numerous complaints about the GFE and the HUD-1 I have fielded over the past 30 months, the issue of greatest concern may be the new integrated mortgage loan disclosures. The proposed rule for the Loan Estimate and Closing Disclosure covers 1,099 pages. Reading the proposal, gaining an understanding of the requirements, and trying your hand at completing the […]

DOES THE CFPB REALLY WANT COMMENTS FROM COMMUNITY BANKERS?

The Consumer Financial Protection Bureau (CFPB) has cranked out more than 2,400 pages of new proposed regulations since July 9th. That is a lot to review in a short period of time. Let’s put this into context. The CFPB had two hours to draft each page starting from the date the Dodd-Frank Act became law. If you give the CFPB the benefit of the doubt and don’t start counting days until July 21, 2011, when […]