Recently the Consumer Financial Protection Bureau (CFPB) published the final list of counties designated as rural or underserved. This final list is identical to the preliminary list published on March 12. The list is used to determine if escrows are required for certain higher-priced mortgage loans. Escrow rules for higher-priced mortgage loans (HPMLs) are scheduled to go into effect on June 1, 2013. The rules require creditors to create and maintain escrow accounts for a […]
Category: Truth in Lending
CFPB AMEND CREDIT CARD ACT RULE FOR STAY-AT-HOME SPOUSES AND PARTNERS
On April 29, 2013 the Consumer Financial Protection Bureau published an 86-page final rule to amend Regulation Z. The final rule has four main elements: First, the final rule generally removes references to an independent ability-to-pay standard from Section 1026.51(a)(1) and associated commentary. As a result, card issuers are no longer required to consider whether consumers age 21 or older have an independent ability to pay; instead, card issuers are now required by Regulation Z […]
DELAY IN CREDIT INSURANCE EFFECTIVE DATE
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 […]
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.