On June 27, 2017, the Consumer Financial Protection Bureau (CFPB) issued two pieces of information related to the 2016 Mortgage Servicing Final Rule: 1) an amendment making non-substantive corrections, and 2) policy guidance related to early compliance with the rule. Final Rule Issuing Corrections The 2016 Mortgage Servicing Final Rule was issued by the CFPB on August 4, 2016, to amend certain provisions of the 2013 Mortgage Servicing Rules. The CFPB is now making corrections […]
Category: Regulation Z
ATR/QM ASSESSMENT
The Dodd-Frank Act (DFA) requires the CFPB to review certain rules within five years after they take effect. The required reviews are called assessments. The CFPB is conducting an assessment of the ATR/QM rule, and will issue a report of the assessment by January 2019. As required by law, the assessment will address the rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act and the specific goals of the […]
TRID AND DAYLIGHT SAVINGS TIME
Daylight Saving Time (DT) begins on March 12, 2017. What does that have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in areas that observe DT need to remember to change the time designation used […]
REVISED SMALL ENTITY COMPLIANCE GUIDE FOR MORTGAGE SERVICING RULES
On November 30, 2016 the Consumer Financial Protection Bureau published an updated version of the Small Entity Compliance Guide entitled Real Estate Settlement Procedures Act (Regulation X) and Truth In Lending Act (Regulation Z) Mortgage Servicing Rules. The Guide is updated to reflect the August 2016 Final Rule that makes significant changes to the servicing rules contained in both regulations. The August 2016 Final Rule changes impact all financial institutions. The impact on small servicers […]
EFFECTIVE DATE FOR FINAL SERVICING RULES ESTABLISHED
On October 19, 2016 the final Servicing Rules published by the Consumer Financial Protection Bureau on August 6, 2016 were finally published in the Federal Register. The final rule clarifies, revises, or amends provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; and prompt crediting and periodic statement requirements under Regulation Z’s servicing provisions. The final rule also addresses proper compliance regarding certain servicing requirements […]