Many bankers have relied on the Federal Reserve Board (FRB) for years as an inexpensive source for the disclosure booklets required for adjustable-rate mortgages. The booklet is frequently referred to as the Consumer Handbook for Adjustable-Rate Mortgages, or CHARM Booklet. Recently it came to my attention that the CHARM Booklet is no longer available through the FRB’s website since the underlying regulation, Regulation Z, has been transferred to the Consumer Financial Protection Bureau (CFPB). However, […]
Category: Lending Compliance
DISABILITY DISCRIMINATION CASE
On January 23, 2013 the Department of Housing and Urban Development (HUD) announced the settlement of a case that alleged that the bank required a loan applicant with disabilities to provide unnecessary documentation to establish he would continue receiving disability income for three years before they would approve his mortgage loan. The applicant submitted documentation from the Social Security Administration as part of his mortgage application. Additional documentation was not needed because Social Security award […]
MATERNITY DISCRIMINATION CASE
On February 6, 2013 the Department of Housing and Urban Development (HUD) announced the settlement of a case that alleged that the lender violated the Fair Housing Act by requiring a home loan applicant on paid maternity leave to return to work before the lender would approve a home loan. HUD’s complaint alleged that because the lender required the woman, a Navy veteran, to return to work before approving the Department of Veterans Affairs (VA)- […]
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 […]
CFPB PUBLISHES LOAN ORIGINATOR COMPENSATION RULES
On January 18, 2013 the Consumer Financial Protection Bureau (CFPB) announced publication of a final rule amending Regulation Z. The new rules 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 rules take effect in January 2014, except that the prohibition on mandatory arbitration and on the […]