Archive

PENDING LENDING ISSUES

Can we see the light at the end of the tunnel? Maybe faintly. Truth-in-Lending/RESPA Integrated Disclosures (TRID) – The biggest pending issue is the TRID rules that are effective August 1, 2015. Some vendors have delivered updates to loan origination software for testing. Policies, procedures, and training need to be completed. But it is appears likely that most lending institutions will complete all required tasks by the deadline. Some, like the banker I talked to […]

CFPB PROPOSAL IMPACTS SMALL CREDITORS AND RURAL AND UNDERSERVED AREAS

On January 29, 2015 the Consumer Financial Protection Bureau (CFPB) proposed several changes to Regulation Z that impact small creditors, particularly in rural and underserved areas. The proposal would increase the number of financial institutions able to offer certain types of Qualified Mortgages (QM) in rural and underserved areas. Ability -to-Repay rules, which took effect in January 2014, require lenders to make a reasonable and good-faith determination that prospective borrowers have the ability to repay […]

FINAL RULE REVISES TIL AND RESPA

On January 18, 2015 the Consumer Financial Protection Bureau (CFPB) approved final changes to Regulations X and Z. The changes are effective on August 1, 2015. The final rule: Extends the timing requirement for revised disclosures when consumers lock a rate or extend a rate lock after the Loan Estimate is provided; Clarifies placement of the Nationwide Mortgage Licensing System and Registry ID (NMLSR ID) on the integrated disclosures; Permits certain language related to construction […]

HOME BORROWERS DON’T SHOP

The Consumer Financial Protection Bureau (CFPB) recently published a blog article reporting the results of their National Survey of Mortgage Borrowers. Key findings from the survey include: Almost half of consumers who take out a mortgage for home purchase fail to shop prior to application; that is, they seriously consider only a single lender or mortgage broker before choosing where to apply. The tendency to shop is somewhat higher among first-time homebuyers. The primary source […]

PROPOSED DEFINITION OF DELINQUENCY

On November 19, 2014 the Consumer Financial Protection Bureau (CFPB) published proposed changes to Regulations X (RESPA) and Z (TIL). Among other items the proposal contains extensive comment on the definition of the term “delinquency” when used for determining when the first notice regarding foreclosure under section 1024.41(f)(1)(i) may be sent. Section 1024.31 contains definitions for various terms that are used throughout the provisions of subpart C of Regulation X. It does not contain a […]