On May 29, 2013 the Consumer Financial Protection Bureau (CFPB) published a final2 rule that amends Regulation Z to delay the June 1, 2013 effective date of a prohibition on creditors financing credit insurance premiums in connection with certain consumer credit transactions secured by a dwelling. The CFPB is delaying the effective date until January 10, 2014, to permit the Bureau to clarify, before the provision takes effect, its applicability to transactions other than those […]
Tag: Dodd-Frank Act
CFPB PUBLISHES THE FINAL FINAL ESCROW RULE (WE HOPE.)
Recently the Consumer Financial Protection Bureau (CFPB) published what we hope is the final final revised rule for escrows on higher-priced mortgage loans (HPMLs). This final final rule amends the final rule the CFPB issued in January 2013. The January final rule lengthened the time for which a mandatory escrow account established for a higher-priced mortgage loan (HPML) must be maintained. The rule also established an exemption from the escrow requirement for certain creditors that operate predominantly […]
DELAY IN CREDIT INSURANCE EFFECTIVE DATE
On May 8 the Consumer Financial Protection Bureau (CFPB) published a proposal to temporarily delay the June 1, 2013, effective date of the prohibition on financing credit insurance premiums in connection with consumer credit transactions secured by a dwelling. The temporary delay provides the CFPB time to clarify, before the provision takes effect, its applicability to transactions other than those in which a lump-sum premium is added to the loan amount at closing. The proposal […]
CFPB PROPOSES MORE CHANGES TO THE QM AND SERVICING CHANGES
On April 19th the Consumer Financial Protection Bureau (CFPB) proposed changes to the Qualified Mortgage (QM) and Servicing Rules. The proposal addresses five topics: Debt-to-Income Ratio Under the Ability to Repay rule, a lender may make a qualified mortgage (QM), a loan for which certain features are prohibited and fees that can be charged are limited. The rule provides for different types of QMs, the main type requiring that a consumer’s debt-to-income ratio (DTI) show […]
PROPOSED REVISION TO 2013 FINAL ESCROW RULE
On April 11, 2013 the Consumer Financial Protection Bureau (CFPB) proposed revisions to the final rule it adopted in January 2013. The proposal clarifies the determination method for the “rural” and “underserved” designations and keeps in place certain existing protections for HPMLs until other similar provisions take effect in January 2014. The January rule can be read to cut off certain existing consumer protections before the new expanded protections take effect. The confusion arose because […]