Section 1026.36(j) states, ” A depository institution must establish and maintain written policies and procedures reasonably designed to ensure and monitor the compliance of the depository institution, its employees, its subsidiaries, and its subsidiaries’ employees with the requirements of paragraphs (d), (e), (f), and (g) of this section. These written policies and procedures must be appropriate to the nature, size, complexity, and scope of the mortgage lending activities of the depository institution and its subsidiaries.” […]
Tag: Consumer Financial Protection Bureau
SPECIAL RULES FOR SMALL CREDITORS – AFFILIATES
The volume of change to the Truth-in-Lending Act and Regulation Z during the past year has been overwhelming. But in the midst of all the change Congress and the Consumer Financial Protection Bureau made an effort to lighten the load, a bit, for small creditors. So what breaks are available? And, who qualifies as a small creditor? Since the definition focuses, in part, on affiliates we are also concerned with who is an affiliate? Breaks […]
STATUS OF HMDA UPDATE
The Dodd-Frank Act has made substantial changes to the Home Mortgage Disclosure Act (HMDA). Now it appears that the regulation writing process is in high gear. Recently Richard Cordray, Director of the Consumer Financial Protection Bureau (CFPB), announced his agency is convening a Small Business Review Panel, as required by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA). The convening of a SBREFA panel is a preliminary step in the process of releasing […]
PROVIDING THE LIST OF HOMEOWNERSHIP COUNSELORS
On November 8 the Consumer Financial Protection Bureau (CFPB) released a tool that provides an easy-to-use method of providing the required list of homeownership counseling organizations. Creditors can provide the list made available through the CFPB tool or may develop their own lists using the same HUD data that the CFPB uses in the tool. Some loans origination software systems (LOS) have not completed links in their software to automatically download the lists. As an […]
REVISED COMPLIANCE BROCHURE AND BOOKLETS
On January 6, 2014 the Consumer Financial Protection Bureau (CFPB) published three revised consumer publications, including a consumer information brochure and two booklets required under the Real Estate Settlement Procedures Act (RESPA), Regulation X, the Truth in Lending Act (TILA), and Regulation Z. These publications are titled: (1) What You Should Know About Home Equity Lines of Credit (HELOC Brochure); (2) Consumer Handbook on Adjustable-Rate Mortgages (CHARM Booklet); and (3) Shopping for Your Home Loan, […]