On January 18, 2015 the Consumer Financial Protection Bureau (CFPB) approved final changes to Regulations X and Z. The changes are effective on August 1, 2015. The final rule: Extends the timing requirement for revised disclosures when consumers lock a rate or extend a rate lock after the Loan Estimate is provided; Clarifies placement of the Nationwide Mortgage Licensing System and Registry ID (NMLSR ID) on the integrated disclosures; Permits certain language related to construction […]
Category: RESPA
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 […]
CFPB – FIRST SERVICING CONSENT ORDER
On September 29. 2014 the Consumer Financial Protection Bureau (CFPB) took action against Michigan-based Flagstar Bank for violating the new mortgage servicing rules contained in Section 1024 of Regulation X, which implements the Real Estate Settlement Procedures Act (RESPA), by illegally blocking borrowers’ attempts to save their homes. The loans were primarily owned by investors and were serviced by Flagstar under contract. The consent order alleges the bank took excessive time to process borrowers’ applications […]
EQUAL TREATMENT FOR SAME-SEX MARRIED COUPLES
On June 26, 2013, in United States v. Windsor, the U.S. Supreme Court struck down Section 3 of the Defense of Marriage Act as unconstitutional. The Consumer Financial Protection Bureau (CFPB) has noted on its blog that the decision has important consequences for its work. In order to fully implement the decision, the CFPB has taken steps to clarify how the decision affects the rules for which the agency is responsible. Recently, CFPB Director Cordray issued a […]