Discount points have been in the news recently. A recent article from the Federal Reserve citied possible UDAAP and Fair Lending violations resulting from unearned discount points. Revisions to Regulation Z, emanating from the Dodd-Frank Act, change the whole game with points. So why the current emphasis on the age-old practice of charging points? Discount Points Primer – Many lenders offer borrowers the option of obtaining a lower interest rate on a mortgage loan by paying […]
Tag: Dodd-Frank Act
YOUR ASSIGNMENT: TEST INTEGRATED MORTGAGE LOAN DISCLOSURES
The volume of changes from the Dodd-Frank Act that are currently unfolding is daunting. Based on the numerous complaints about the GFE and the HUD-1 I have fielded over the past 30 months, the issue of greatest concern may be the new integrated mortgage loan disclosures. The proposed rule for the Loan Estimate and Closing Disclosure covers 1,099 pages. Reading the proposal, gaining an understanding of the requirements, and trying your hand at completing the […]
DOES THE CFPB REALLY WANT COMMENTS FROM COMMUNITY BANKERS?
The Consumer Financial Protection Bureau (CFPB) has cranked out more than 2,400 pages of new proposed regulations since July 9th. That is a lot to review in a short period of time. Let’s put this into context. The CFPB had two hours to draft each page starting from the date the Dodd-Frank Act became law. If you give the CFPB the benefit of the doubt and don’t start counting days until July 21, 2011, when […]
INTERAGENCY PROPOSAL FOR APPRAISALS FOR HIGHER-RISK MORTGAGES
On August 15, 2012 the Federal Reserve Board, the Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively, the Agencies) jointly proposed to amend Regulation Z, to implement a Dodd-Frank Act provision requiring appraisals for “higher-risk mortgages.” Comments are due on or before October 15, 2012. The 211-page proposed rule generally defines a “higher-risk mortgage” as a closed-end consumer […]
PROPOSED REGULATION B APPRAISAL RULE
How refreshing to get a proposal from the CFPB that totals less than 100 pages. On August 15, 2012 the Consumer Financial Protection Bureau (CFPB) published a 58-page release that contains proposed rules to implement a Dodd-Frank Act requirement that amends appraisal rules to help inform mortgage applicants on how a creditor determines a property’s value prior to closing on the mortgage. It will also make it easier for loan applicants to determine if a loan […]