Effective on January 10, 2014 Section 1026.20 of Regulation Z requires, when a rate change accompanied by a payment change occurs on an ARM, a notice to be sent to the consumer at least 60, but no more than 120, days before the first payment at the adjusted level is due. However a different timing rule (at least 25, but no more than 120, days before the first payment at the adjusted level is due) applies […]
Category: Regulation Z
PROPOSED DEFINITION OF DELINQUENCY
On November 19, 2014 the Consumer Financial Protection Bureau (CFPB) published proposed changes to Regulations X (RESPA) and Z (TIL). Among other items the proposal contains extensive comment on the definition of the term “delinquency” when used for determining when the first notice regarding foreclosure under section 1024.41(f)(1)(i) may be sent. Section 1024.31 contains definitions for various terms that are used throughout the provisions of subpart C of Regulation X. It does not contain a […]
PROPOSED CHANGES TO REGULATIONS X AND Z
Earlier this week the Consumer Financial Protection Bureau published proposed changes to Regulations X (RESPA) and Z (TIL). The proposed changes focus primarily on clarifying, revising, or amending provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; and periodic statement requirements under Regulation Z’s servicing provisions. Extensive proposed comment appears on the definition of the term “delinquency” when used, among other purposes, for determining when […]
PROPOSED CHANGES TO INTEGRATED DISCLOSURE RULES
On October 14, 2014 the Consumer Financial Protection Bureau (CFPB) issued a proposal to modify the final rule published last November. The proposal touches on two issues. Revised Loan Estimate After Rate Lock The proposal gives creditors some extra time to provide consumers with revised Loan Estimates after a consumer locks a floating interest rate. Under current integrated disclosure rules, when consumers lock their interest rates, creditors are required to give them a revised Loan […]
INTERAGENCY GUIDANCE ON HELOCS NEARING THEIR END-OF-DRAW PERIODS
On July 1, 2014 the federal financial institution regulatory agencies published guidance regarding the risk associated with Home Equity Lines of Credit (HELOCs) transitioning from their draw periods to full repayment. This is not a new issue. HELOCs have been part of product mix for financial institutions since the 1980s. Most HELOCs have a five or ten year draw period. During the draw period, a borrower has revolving access to unused amounts under a specified […]