On May 10, 2018 the Consumer Financial Protection Bureau (CFPB) published its semi-annual regulatory agenda. The agenda includes rulemaking actions in pre-rule, proposed rule, final rule, long-term, inactive, and completed stages. Priorities are clearly changing. The agency’s Acting Director has decided to reclassify as “inactive” certain rulemakings that had been listed in previous editions of the agenda in the expectation that final decisions on whether and when to proceed with such projects will be made […]
Tag: CFPB
CFPB FINAL RULE CLARIFIES REGULATORY BLACK HOLE
On April 28, 2018 the Consumer Financial Protection Bureau (CFPB) finalized an amendment to its Truth in Lending/Real Estate Settlement Procedures Act Integrated Disclosures (TRID) that addresses when a creditor may compare charges paid by or imposed on the consumer to amounts disclosed on a Closing Disclosure, instead of a Loan Estimate, to determine if an estimated closing cost was disclosed in good faith. Under the current rule, circumstances may arise in which a cost […]
UPDATED MORTGAGE SERVICING FAQS
On March 20, 2018 the Consumer financial Protection bureau (CFPB) updated the Mortgage Servicing FAQs. The updated FAQs pertain to compliance with Regulation X and Regulation Z, effective April 19, 2018. The updates deal primarily with recent revisions to Regulation that are effective on April 19, 2018. Read More: A copy of the FAQs is available at: https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_mortgage-servicing_frequently-asked-questions.pdf More information about the recent changes to Regulation Z are available at: https://mycomplianceresource.com/last-minute-revisions-to-regulation-z-servicing-rules/
LAST MINUTE REVISIONS TO REGULATION Z SERVICING RULES
On March 6, 2018 the Consumer Financial Protection Bureau (CFPB) issued a final rule to help mortgage servicers communicate with certain borrowers facing bankruptcy. The revisions to Regulation Z give mortgage servicers more latitude in providing periodic statements to consumers entering or exiting bankruptcy, as required by the Bureau’s 2016 mortgage servicing rule. The 2016 mortgage servicing rule requires that servicers send modified periodic statements or coupon books to certain consumers in bankruptcy starting April 19, 2018. […]
HOUSE PASSES BILLS TO ELIMINATE THE “MADDEN ISSUE”
In 2016 the Second Circuit Court of Appeals’(NY, Connecticut, and Vermont) recent decision in Madden v. Midland Funding, LLC held that a nonbank entity taking assignment of debts originated by a national bank is not entitled to protection under the National Bank Act (“NBA”) from state-law usury claims. Apparently, the Court did not considered the “Valid-When-Made Doctrine”—a longstanding principle of usury law that if a loan is not usurious when made, then it does not […]