The Consumer Financial Protection Bureau (CFPB) just completed the usual year-end chore of updating various thresholds. The changes are based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) for various periods in 2013. Escrow Exemption for HPMLs – On December 30, 2013 the CFPB amended the official commentary that interprets the requirements of Regulation Z (Truth in Lending) to reflect a change in […]
Category: Regulation Z
HMDA – HOEPA STATUS
Section 1003.4(a)(13) of Regulation C requires that the Loan Application Register indicate, among other items, whether the loan is subject to the Home Ownership and Equity Protection Act of 1994 (HOEPA), as implemented in Regulation Z (12 CFR 1026.32). Under current rules a loan secured by a consumer’s principal dwelling is subject to HOEPA if the loan has a high rate or high fees. Currently a loan has high fees if the total points and […]
REVISED HPML APPRAISAL RULES
On December 12, 2013 the Federal Reserve Board, The Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the National Credit Union Administration, and the Office of the Comptroller of the Currency jointly published a final rule that creates exemptions from certain appraisal requirements for a subset of higher-priced mortgage loans. The exemptions are intended to save borrowers time and money while still ensuring that the loans are financially sound. […]
NEW INTEGRATED DISCLOSURES RELEASED
On October 20, 2013 the Consumer Financial Protection Bureau published the new rules for the integrated disclosures. The new rule is 1,888 pages long and is effective on August 1, 2015. The CFPB is not revising finance charge rules at this time. A copy of the new rule is available here.
KNOW BEFORE YOU OWE: MORTGAGES
As we recently reported, today is a big day for mortgage lenders. The Consumer Financial Protection Bureau (CFPB) is releasing the new integrated disclosures in conjunction with a field meeting scheduled at 11:00 a.m. in Boston. The new Loan Estimate form combines the good faith estimate and the early TIL disclosure. The new Closing disclosure combines the HUD-1 and the final TIL disclosure. The good news is that use of the new forms will not […]