Earlier this week the Consumer Financial Protection Bureau published proposed changes to Regulations X (RESPA) and Z (TIL). The proposed changes focus primarily on clarifying, revising, or amending provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; and periodic statement requirements under Regulation Z’s servicing provisions. Extensive proposed comment appears on the definition of the term “delinquency” when used, among other purposes, for determining when […]
Tag: Consumer Financial Protection Bureau
VERIFYING SOCIAL SECURITY DISABILITY INCOME
Earlier this week the Consumer Financial Protection Bureau (CFPB) published a article and issued a bulletin on the topic of Social Security disability income. In our November 10th article on the same topic we warned you of the discrimination risk involved in verifying this type of income. Now you can hear the same message from the CFPB. In the past, Social Security disability income recipients have faced special challenges in providing proof that their disability […]
PROPOSED CHANGES TO INTEGRATED DISCLOSURE RULES
On October 14, 2014 the Consumer Financial Protection Bureau (CFPB) issued a proposal to modify the final rule published last November. The proposal touches on two issues. Revised Loan Estimate After Rate Lock The proposal gives creditors some extra time to provide consumers with revised Loan Estimates after a consumer locks a floating interest rate. Under current integrated disclosure rules, when consumers lock their interest rates, creditors are required to give them a revised Loan […]
CFPB – FIRST SERVICING CONSENT ORDER
On September 29. 2014 the Consumer Financial Protection Bureau (CFPB) took action against Michigan-based Flagstar Bank for violating the new mortgage servicing rules contained in Section 1024 of Regulation X, which implements the Real Estate Settlement Procedures Act (RESPA), by illegally blocking borrowers’ attempts to save their homes. The loans were primarily owned by investors and were serviced by Flagstar under contract. The consent order alleges the bank took excessive time to process borrowers’ applications […]
PROPOSED REPEAL OF REGULATION AA
On August 22, 2014 the Federal Reserve Board requested comment on a proposal to repeal its Regulation AA (Unfair or Deceptive Acts or Practices). Also on Friday, the Board, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency issued guidance clarifying that the repeal of the credit practices rules applicable to banks, savings associations, and federal credit unions is not a determination that the […]