Better late than never! Yesterday the Consumer Financial Protection Bureau provided long-awaited guidance (CFPB Bulletin 2012-02) on the Regulation Z Loan Originator Compensation rules that were effective in April 2011. The Compensation Rules provide that no loan originator may receive (and no person may pay to a loan originator), directly or indirectly, compensation that is based on any terms or conditions of a mortgage transaction. The Commentary to the Regulation clarifies that compensation includes salaries, […]
Category: Financial Reform
FINALLY, A DIRECTOR FOR THE CFPB – MAYBE
In a speech in Ohio, on Wednesday afternoon President Obama announced that he would install Richard Cordrey as the head of the Consumer Financial Protection Bureau (CFPB) through a recess appointment. Last summer the president selected Cordray, a former Ohio attorney general, to direct the Consumer Financial Protection Bureau, but Senate Republicans have continued to block a vote on his nomination. GOP lawmakers have argued that the bureau should be accountable to Congress. Republicans are […]
FINALLY – MOVEMENT FROM THE CFPB
On November 29th the Consumer Financial Protection Bureau (CFPB) published a notice and request for information about streamlining the inherited regulations. This publication is significant for several reasons. INHERITED REGULATIONS The “inherited regulations” include 14 existing consumer regulations, including, among others, Regulation Z and Regulation X (RESPA), that the CFPB inherited from other regulatory agencies on July 21, 2011. The inherited regulations will be published in Chapter X of Title 12 of the Code of […]
THE POLITICAL CIRCUS
The Dodd-Frank Act is one the most significant pieces of legislation to ever impact the banking industry. Our lives would be much simpler if the law never happened, but the law did happen and we all have to deal with it. Instead of dealing with the law in a quick decisive manner Congress and the current administration have turned it into a political circus. Dodd-Frank became law on July 21, 2010. The law contains hundreds […]
REGULATION Z – LOAN ORIGINATOR COMPENSATION RULES
Everyone seems aware that Regulation Z rules, which were effective on April 1, 2011, state that no loan originator shall receive and no person shall pay to a loan originator, directly or indirectly, compensation in an amount that is based on any of the transaction’s terms or conditions. Everyone also seems aware that the term “compensation” includes salaries, commissions, and any financial or similar incentive provided to a loan originator that is based on any […]