On September 13 the Consumer Financial Protection Bureau published it latest revisions to final rules that were published last January. The 274-page final rule: Revises error resolution procedures and information requests (§§ 1024.35 and 1024.36), and loss mitigation (§ 1024.41). With respect to loss mitigation, two of the revisions concern the requirement in § 1024.41(b)(2)(i) that a servicer review a borrower’s loss mitigation application within five days and provide a notice to the borrower acknowledging […]
Category: Regulation Z
MOST RECENT CFPB SEMI-ANNUAL RULEMAKING AGENDA
Recently the Consumer Financial Protection Bureau (CFPB) published its most recent semiannual rulemaking agenda. There were no big surprises in the agenda. This article reviews three issues of concern. Integrated Disclosures and Finance Charge Rules – The biggest rules yet to be finalized are the new integrated disclosures. The disclosures include the loan estimate (that combines the early TIL disclosure and the good faith estimate) and the closing disclosure (that combines the final TIL disclosures […]
PROPOSED REVISIONS TO HIGHER-PRICED MORTGAGE LOAN APPRAISAL RULES
Recently the Board of Governors of the Federal Reserve System; Bureau of Consumer Financial Protection; Federal Deposit Insurance Corporation; Federal Housing Finance Agency; National Credit Union Administration; and Office of the Comptroller of the Currency (collectively, the Agencies). proposed additional changes to the Higher-Priced Mortgage Loan appraisal rules that were published January 18, 2013. The comment period for the proposal ends on September 9, 2013. The January Rule requires creditors to obtain an appraisal or […]
REVISED REGULATION Z EXAMINATION PROCEDURES
Recently the federal financial institution regulatory agencies released updated Regulation Z Examination procedures. The revised interagency examination procedures reflect amendments implementing revisions to the Truth in Lending Act under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) that: (1) restrict mandatory arbitration agreements in mortgage loans; and (2) revise existing escrow requirements on first-lien higher-priced mortgage loans. These amendments are effective with respect to transactions for which the creditor receives an application […]
CFPB PROPOSES CHANGES TO REGULATIONS B, X, AND Z
On June 24, 2013 the Consumer Financial Protection Bureau published proposed changes to several final rules originally published in January 2013. The proposal would: Provide procedures for obtaining follow-up information on loss-mitigation applications; Make it easier for servicers to offer short-term forbearance plans; Revise the definitions of “rural” and “underserved” and provide interim rules until the revised definitions are complete; Provide clarification about financing credit insurance; Clarify the definition of “loan originator;” Clarify the definition […]