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Recently the Consumer Financial Protection Bureau (CFPB) published its most recent semiannual rulemaking agenda. There were no big surprises in the agenda. This article reviews three issues of concern. Integrated Disclosures and Finance Charge Rules – The biggest rules yet to be finalized are the new integrated disclosures. The disclosures include the loan estimate (that combines the early TIL disclosure and the good faith estimate) and the closing disclosure (that combines the final TIL disclosures […]

Recently the Board of Governors of the Federal Reserve System; Bureau of Consumer Financial Protection; Federal Deposit Insurance Corporation; Federal Housing Finance Agency; National Credit Union Administration; and Office of the Comptroller of the Currency (collectively, the Agencies). proposed additional changes to the Higher-Priced Mortgage Loan appraisal rules that were published January 18, 2013. The comment period for the proposal ends on September  9, 2013. The January Rule requires creditors to obtain an appraisal or […]

Can a servicer offset the balance in an escrow account against the payoff balance quoted to the borrower? The answer depends on whether the transaction occurs today or after January 10, 2014. Today – If the transaction occurs today, Section 1024.17 (i)(4)(iii) states, “If a borrower pays off a mortgage loan during the escrow account computation year, the servicer shall submit a short year statement to the borrower within 60 days after receiving the pay-off funds. […]

Recently the federal financial institution regulatory agencies released updated Regulation Z Examination procedures. The revised interagency examination procedures  reflect amendments implementing revisions to the Truth in Lending Act under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) that:  (1) restrict mandatory arbitration agreements in mortgage loans; and (2) revise existing escrow requirements on first-lien higher-priced mortgage loans.  These amendments are effective with respect to transactions for which the creditor receives an application […]