On November 29th the Consumer Financial Protection Bureau (CFPB) published a notice and request for information about streamlining the inherited regulations. The “inherited regulations” include 14 existing consumer regulations that the CFPB inherited from other regulatory agencies on July 21, 2011, including, among others, Regulation Z (Truth in Lending) and Regulation X (RESPA). The inherited regulations are published in Chapter X of Title 12 of the Code of Federal Regulations. Following is the schedule of […]
Category: Truth in Lending
KNOW BEFORE YOU OWE
The Dodd-Frank Act requires the Consumer Financial Protection Bureau (CFPB) to combine Truth in Lending Act and the Real Estate Settlement Procedures Act disclosures. The CFPB began with the early disclosures (the combined early TIL and GFE). Now they are working on the closing disclosures (the combined TIL/HUD-1). Early disclosures – For most lenders the early TIL and GFE disclosures currently include four to six pages. The proposed combined form consists of two pages. The […]
STUDENT LOAN – KNOW BEFORE YOU OWE
The CFPB is assisting the Department of Education with creating a “financial aid shopping sheet” that colleges could use to improve information for students and their families. The draft shopping sheet is posted on the CFPB website, where comments from students, families, and other stakeholders are sought. It includes estimated monthly payments after leaving school and helpful school-related information such as graduation rates. And, importantly, it allows students to compare an offer from one school […]
REGULATION Z – LOAN ORIGINATOR COMPENSATION RULES
Everyone seems aware that Regulation Z rules, which were effective on April 1, 2011, state that no loan originator shall receive and no person shall pay to a loan originator, directly or indirectly, compensation in an amount that is based on any of the transaction’s terms or conditions. Everyone also seems aware that the term “compensation” includes salaries, commissions, and any financial or similar incentive provided to a loan originator that is based on any […]
ABILITY TO REPAY – PROPOSED REGULATIONS
Recently the Federal Reserve Board (FRB) requested comment on a proposed rule under Regulation Z that requires creditors to determine a consumer’s ability to repay a mortgage before making the loan and also establishes minimum mortgage underwriting standards. We already have a similar requirement for Section 32 mortgages, Section 35 mortgages (higher-priced mortgage loans), and for open-end credit. The requirement is being expanded to all consumer mortgage loans (except home equity lines of credit, timeshare […]