On May 8 the Consumer Financial Protection Bureau (CFPB) published a proposal to temporarily delay the June 1, 2013, effective date of the prohibition on financing credit insurance premiums in connection with consumer credit transactions secured by a dwelling. The temporary delay provides the CFPB time to clarify, before the provision takes effect, its applicability to transactions other than those in which a lump-sum premium is added to the loan amount at closing. The proposal […]
Category: Regulation Z
CFPB PROPOSES MORE CHANGES TO THE QM AND SERVICING CHANGES
On April 19th the Consumer Financial Protection Bureau (CFPB) proposed changes to the Qualified Mortgage (QM) and Servicing Rules. The proposal addresses five topics: Debt-to-Income Ratio Under the Ability to Repay rule, a lender may make a qualified mortgage (QM), a loan for which certain features are prohibited and fees that can be charged are limited. The rule provides for different types of QMs, the main type requiring that a consumer’s debt-to-income ratio (DTI) show […]
CFPB PUBLISHES REGULATION Z ESCROW GUIDANCE
On April 19th the Consumer Financial Protection Bureau (CFPB) published TILA Escrow Rule Small Entity Compliance Guide. The 21- page Guide provides a summary of the TILA Escrow Rule. The guide also highlights issues that small creditors might find helpful to consider when implementing the rule. The Guide is available here.
PROPOSED REVISION TO 2013 FINAL ESCROW RULE
On April 11, 2013 the Consumer Financial Protection Bureau (CFPB) proposed revisions to the final rule it adopted in January 2013. The proposal clarifies the determination method for the “rural” and “underserved” designations and keeps in place certain existing protections for HPMLs until other similar provisions take effect in January 2014. The January rule can be read to cut off certain existing consumer protections before the new expanded protections take effect. The confusion arose because […]
CFPB ABILITY TO REPAY AND QM GUIDANCE
On April 10, 2013 the Consumer Financial Protection Bureau published two compliance tools to assist financial institutions with implementation of the ability to repay and the qualified mortgage rules. The first tool is a 45-page booklet entitled Ability-to-Repay and Qualified Mortgage Rule – Small Entity Compliance Guide. The Guide is available here. The second tool is a 1½ page chart entitled General Comparison of Ability-to-Repay Requirements with Qualified Mortgages. The chart is available here.