On May 2, 2019 the Consumer Financial Protection Bureau (CFPB) published a Notice of Proposed Rulemaking (NPRM), an Advanced Notice of Proposed Rulemaking (ANPR) and other items related to changes to Regulation C, which is the implementing regulation for the Home Mortgage Disclosure Act. Notice of Proposed Rulemaking For closed-end mortgage loans, the NPRM proposes two alternatives that would permanently increase the coverage threshold from 25 to either 50 or 100 closed-end mortgage loans. For […]
Tag: CFPB
TRID ASSUMPTIONS FACT SHEET
On May 1 the Consumer Financial Protection Bureau (CFPB) published a fact sheet entitled Are Loan Estimates and Closing Disclosures Required for Assumptions? The factsheet consists of two parts: (1) a flowchart; and (2) a narrative discussion. The flowchart is a quick reference that highlights the major questions to be answered when determining if a Loan Estimate and Closing Disclosure are required for the assumption transactions described above. The narrative discussion provides general information that […]
CFPB RELEASES MODIFIED LARS
On March 29, the CFPB announced that the HMDA Modified Loan Application Register (LAR) data have been published for approximately 5,400 financial institutions. This is the first year in which additional data reported by certain institutions under the 2015 HMDA rule are available. The Modified LARs contain loan level information for 2018 on individual HMDA filers, modified to protect privacy. A copy of the CFPB’s press release is available here. The 2018 HMDA Modified LARs are […]
PACE FINANCING – ADVANCED NOTICE OF PROPOSED RULEMAKING
On May 24, 2018 the Economic Growth, Regulatory Relief, and Consumer Protection Act was signed into law. Among its many provisions Section 307 amends the Truth in Lending Act (TILA) to mandate that the Consumer Financial Protection Bureau (CFPB) prescribe certain regulations relating to residential Property Assessed Clean Energy (PACE) financing. Specifically, the regulations must carry out the purposes of TILA’s ability-to-repay (ATR) requirements, currently in place for residential mortgage loans, with respect to PACE […]
CFPB LAUNCHES SYSTEM FOR SUBMISSION OF PREPAID ACCOUNT AGREEMENTS
On February 27, 2019 the Consumer Financial Protection Bureau (CFPB) launched a streamlined electronic submission system, called Collect, which allows prepaid account issuers to submit their account agreements to the Bureau. Prepaid issuers can register for the system now before the April 1, 2019 effective date of the Bureau’s prepaid rule. The Bureau’s prepaid rule includes a requirement that prepaid account issuers submit their prepaid account agreements, including fee information, to the Bureau. Starting on […]