The Dodd-Frank Act (DFA) requires the CFPB to review certain rules within five years after they take effect. The required reviews are called assessments. The CFPB is conducting an assessment of the ATR/QM rule, and will issue a report of the assessment by January 2019. As required by law, the assessment will address the rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act and the specific goals of the […]
Tag: Consumer Financial Protection Bureau
JUST A LITTLE OVER THE LIMIT
From time-to-time I have identified a practice as “a violation, but a low-risk violation.” That’s kind of like driving 58 miles per hour in a 55 miles per hour zone. It is “a violation of law, but a low-risk violation.” Recently I was asked if it was OK to take a realtor to lunch to build a better relationship that should lead to more referrals of loan applications. I responded that the practice is… You […]
CFPB SERVICING RULE FIASCO
On May 4th the Consumer Financial Protection Bureau (CFPB) announced plans to assess the effectiveness of the Real Estate Settlement Procedures Act (RESPA) mortgage servicing rule. The announcement accurately reports that the CFPB issued the 2013 RESPA Servicing Final Rule in January 2013. That rule was amended a few times before it took effect on January 10, 2014. The Dodd-Frank Act requires the CFPB to conduct assessments of certain rules within five years after they […]
HMDA CLARIFICATION
On April 13, 2017 the Consumer Financial Protection Bureau published 150-page proposed update to Regulation C. The changes should help financial institutions comply with the 2015 HMDA Final Rule by clarifying the information they are required to collect and report about their mortgage lending. The proposal contains a number of clarifications, technical corrections, and minor changes to the HMDA regulation. These include clarifying certain key terms, such as “temporary financing” and “automated underwriting system.” The […]
HMDA – HUGE ERRORS, HUGE PENALTIES
Recently the Consumer Financial Protection Bureau (CFPB) ordered Nationstar Mortgage LLC, of Coppell, Texas, to pay a $1.75 million civil penalty for violating the Home Mortgage Disclosure Act (HMDA) by consistently failing to report accurate data about mortgage transactions for 2012 through 2014, and to take the necessary steps to improve its compliance management and prevent future violations. This is the largest HMDA penalty ever imposed by the CFPB. According to 2014 data, Nationstar was […]