On September 29. 2014 the Consumer Financial Protection Bureau (CFPB) took action against Michigan-based Flagstar Bank for violating the new mortgage servicing rules contained in Section 1024 of Regulation X, which implements the Real Estate Settlement Procedures Act (RESPA), by illegally blocking borrowers’ attempts to save their homes. The loans were primarily owned by investors and were serviced by Flagstar under contract. The consent order alleges the bank took excessive time to process borrowers’ applications […]
Category: Regulation X
EQUAL TREATMENT FOR SAME-SEX MARRIED COUPLES
On June 26, 2013, in United States v. Windsor, the U.S. Supreme Court struck down Section 3 of the Defense of Marriage Act as unconstitutional. The Consumer Financial Protection Bureau (CFPB) has noted on its blog that the decision has important consequences for its work. In order to fully implement the decision, the CFPB has taken steps to clarify how the decision affects the rules for which the agency is responsible. Recently, CFPB Director Cordray issued a […]
CFPB REGULATORY PRIORITIES FROM THE SEMIANNUAL REGULATORY AGENDA
The CFPB’s regulatory priorities for the semiannual period ending October 31, 2014, include continuing work to implement Dodd-Frank Act mortgage protections, a series of rulemakings to address critical issues in other markets for consumer financial products and services, and following up on earlier efforts to streamline and modernize regulations that the CFPB has inherited from other Federal agencies. Implementing Dodd-Frank Act Mortgage Protections A major effort of the CFPB is the implementation of its […]
IMPLEMENTING THE NEW INTEGRATED DISCLOSURES – Part II
As explained in the first part of this article implementing the new integrated disclosures is a massive task. Lenders that have a plan and get an early start on the process will complete the task by the August 1, 2015 deadline with minimal stress to all involved. We advocate a three-step process for implementing the New disclosures. Master the Material – Mastering 1,888 pages of regulation and related material doesn’t happen quickly. Most of us […]
AFFORDABILITY ACT – CONTROVERSY ON DETACHED STRUCTURES
On March 23 Congress passed the Homeowner Flood Insurance Affordability Act. The Affordability Act revises certain sections of Biggert-Waters, eliminates or delays other sections and creates new rules. Section 13 of the Affordability Act is causing some controversy. It adds: The following exclusion to Subsection (c) of section 102 of the Flood Disaster Protection Act of 1973: (3) DETACHED STRUCTURES.—Notwithstanding any other provision of this section, flood insurance shall not be required, in the case […]