While the Consumer Financial Protection Bureau (CFPB) has been developing and testing the combined TIL/RESPA forms a number of issues have come to their attention. Following are a few items in their crosshairs: Many lenders and mortgage brokers provide consumers with preliminary estimates of loan terms and settlement costs that are not mandated by TILA or RESPA. The CFPB is considering whether to require that these preliminary estimates carry a disclaimer that tells the consumer […]
Category: Truth in Lending
LOAN ORIGINATOR COMPENSATION RULES
The rules, which were effective April 1, 2011, restrict the methods available to compensate mortgage loan originators. The rules are confusing. Interpretations are lacking. The rules were issued by the Federal Reserve Board, but then in July authority for Regulation Z transferred from the Federal Reserve to the Consumer Financial Protection Bureau (CFPB). The CFPB has not issued any interpretations for the regulations it inherited from the the agencies. But issues and questions persist, especially […]
NEW MONTHLY STATEMENTS FOR MORTGAGE LOANS
The next chapter in the future of mortgage lending was published by the Consumer Financial Protection Bureau (CFPB) this week. As required by the Dodd-Frank mortgage lenders and related parties soon will be required to give borrowers with closed-end mortgage loans a statement for each billing cycle. Many financial institutions already provide statements. Currently there is no standard format for statements. Section 1420 of the Dodd-Frank Act amends the Truth in Lending Act by requiring […]
STATUS OF CFPB’s COMBINED MORTGAGE DISCLOSURES
Several months ago, the Consumer Financial Protection Bureau (CFPB) published in its blog two sample closing disclosures that combine final Truth in Lending (TIL) disclosures with HUD-1 disclosures. They requested that consumers and industry members compare two prototypes for the disclosures and vote on the preferred option. Now the CFPB is asking consumers and industry members to look specifically at how the new closing disclosure prototypes work with the application disclosure prototype, which was pretty […]
THE CFPB INHERITS REGULATION Z
Congress enacted the Truth in Lending Act (TILA) in 1968 based on findings that the informed use of credit resulting from consumers’ awareness of the cost of credit would enhance economic stability and would strengthen competition among consumer credit providers. One of the purposes of TILA is to provide meaningful disclosure of credit terms to enable consumers to compare credit terms available in the marketplace more readily and avoid the uninformed use of credit. TILA […]