The Consumer Financial Protection Bureau (CFPB) has issued a 23-page proposed regulation to delay the Truth in Lending/RESPA Integrated Disclosures from August 1, 2015 to October 3, 2015. The delay is appreciated, but some of the explanations are just weird. The delay occurred because a CFPB staffer forgot to send a notice to Congress 60 days prior to the August 1st effective date. By the time the error was discovered a two-week delay, until August […]
Category: Lending Compliance
JOINT AGENCIES ISSUE FINAL RULE ON FLOOD INSURANCE
The joint agencies (OCC, Federal Reserve Board, FDIC, Farm Credit Administration and NCUA) recently approved a final rule that modifies the regulation for loans secured by property located in a special flood hazard area. The final rule implements certain provisions that were established under the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) such as the requirement to escrow for flood insurance premiums on residential improved real estate securing a loan, as well as, an […]
TRID DELAY
Today, within hours after the Consumer Financial Protection Bureau (CFPB) announced to 1,700 bankers at the ABA Regulatory Compliance Conference that there would be no delays in TRID (TIL/RESPA Integrated Disclosure Rule) implementation, CFPB Director Richard Cordray issued the following statement: “The CFPB will be issuing a proposed amendment to delay the effective date of the Know Before You Owe rule until October 1, 2015. We made this decision to correct an administrative error that […]
CFPB CHANGES APR TOLERANCES OR NOT
During a May 12 speech at the National Association of Realtors conference in Washington, D.C. CFPB Director Richard Cordray took the time to dismiss some misconceptions regarding the TRID Truth in Lending Act/Real Estate Settlement Procedures Act Integrated Disclosures and he created a few misconceptions in the process. Director Cordray said the requirement to provide the new Closing Disclosure three business days before closing “should not interfere with a successful closing, as some have claimed. […]
TRID DELAY – NOT LIKELY
It is that season again. Every time we approach the effective date of a major regulatory change various financial institution associations make last-ditch efforts to delay the changes or the impact of the changes. The outcome is always the same – nothing changes. The Truth-in-Lending/RESPA Integrated Disclosures (TRID) changes are no exception. Recently the American Bankers Association (ABA) petitioned the Consumer Financial Protection Bureau (CFPB) to provide a grace period that would allow more time […]