Archive

CFPB REGULATORY PRIORITIES FROM THE SEMIANNUAL REGULATORY AGENDA

The CFPB’s regulatory priorities for the semiannual period ending October 31, 2014, include continuing work to implement Dodd-Frank Act mortgage protections, a series of rulemakings to address critical issues in other markets for consumer financial products and services, and following up on earlier efforts to streamline and modernize regulations that the CFPB has inherited from other Federal agencies.   Implementing Dodd-Frank Act Mortgage Protections A major effort of the CFPB is the implementation of its […]

IMPLEMENTING THE NEW INTEGRATED DISCLOSURES – Part II

As explained in the first part of this article implementing the new integrated disclosures is a massive task. Lenders that have a plan and get an early start on the process will complete the task by the August 1, 2015 deadline with minimal stress to all involved.  We advocate a three-step process for implementing the New disclosures. Master the Material – Mastering 1,888 pages of regulation and related material doesn’t happen quickly. Most of us […]

AFFORDABILITY ACT – CONTROVERSY ON DETACHED STRUCTURES

On March 23 Congress passed the Homeowner Flood Insurance Affordability Act. The Affordability Act revises certain sections of Biggert-Waters, eliminates or delays other sections and creates new rules. Section 13 of the Affordability Act is causing some controversy. It adds: The following exclusion to Subsection (c) of section 102 of the Flood Disaster Protection Act of 1973: (3)  DETACHED STRUCTURES.—Notwithstanding any other provision of this section, flood insurance shall not be required, in the case […]

PROVIDING THE LIST OF HOMEOWNERSHIP COUNSELORS

On November 8 the Consumer Financial Protection Bureau (CFPB) released a tool that provides an easy-to-use method of providing the required list of homeownership counseling organizations. Creditors can provide the list made available through the CFPB tool or may develop their own lists using the same HUD data that the CFPB uses in the tool. Some loans origination software systems (LOS) have not completed links in their software to automatically download the lists. As an […]

REVISED COMPLIANCE BROCHURE AND BOOKLETS

On January 6, 2014 the Consumer Financial Protection Bureau (CFPB) published three revised consumer publications, including a consumer information brochure and two booklets required under the Real Estate Settlement Procedures Act (RESPA), Regulation X, the Truth in Lending Act (TILA), and Regulation Z. These publications are titled: (1)  What You Should Know About Home Equity Lines of Credit (HELOC Brochure); (2)  Consumer Handbook on Adjustable-Rate Mortgages (CHARM Booklet); and (3)  Shopping for Your Home Loan, […]