Archive

SERVICING RULES – PREVIEW

Recently the Consumer Financial Protection Bureau outlined major new rules that impact mortgage loan servicing. The rules, which revise the Truth in Lending Act and the Real Estate Settlement Procedures Act, are required by the Dodd-Frank Act. Under the rules servicers must: Provide periodic statements for all residential mortgage loans; Provide a new notice 6 months prior to interest rate reset on ARM loans; Provide notices and establish other requirements for force-placed insurance; Credit payments […]

TALK ABOUT BEING STUCK IN THE MIDDLE

Recently two members of Congress, Neugebauer (R-TX) and Capito (R-WV), asked Richard Cordrey, Director of the Consumer Financial Protection Bureau (CFPB), for assurances that the CFP will conduct a cost-benefit analysis for each rule it enacts, as required by the Dodd-Frank Act. Section 1022 of the Dodd-Frank Act requires the CFPB to consider the potential benefits and costs of any proposed rule. Congress passes the law that requires the CFPB to adopt a new rule. […]

CFPB GUIDANCE ON LOAN ORIGINATOR COMPENSATION

Better late than never! Yesterday the Consumer Financial Protection Bureau provided long-awaited guidance (CFPB Bulletin 2012-02) on the Regulation Z Loan Originator Compensation rules that were effective in April 2011. The Compensation Rules provide that no loan originator may receive (and no person may pay to a loan originator), directly or indirectly, compensation that is based on any terms or conditions of a mortgage transaction. The Commentary to the Regulation clarifies that compensation includes salaries, […]

TIL/RESPA POSSIBILITIES

While the Consumer Financial Protection Bureau (CFPB) has been developing and testing the combined TIL/RESPA forms a number of issues have come to their attention. Following are a few items in their crosshairs: Many lenders and mortgage brokers provide consumers with preliminary estimates of loan terms and settlement costs that are not mandated by TILA or RESPA. The CFPB is considering whether to require that these preliminary estimates carry a disclaimer that tells the consumer […]

CFPB REGULATION STREAMLINING FEEDBACK WEB TOOL

Recently the Consumer Financial Protection Bureau (CFPB) launched the Regulation Streamlining Feedback Web Tool. This tool allows you to give input on ways to streamline the regulations the CFPB inherited under the Dodd-Frank Wall Street Reform and Consumer Protection Act. The CFPB wants to know what parts of these regulations should receive the highest priority for updating, modifying, or eliminating. The Regulation Streamlining Feedback Web Tool enables you to submit comments and suggestions on one […]