Issue – The Bureau of Consumer Financial Protection (Bureau) is proposing to amend Regulation Z. Regulation Z generally limits the total amount of fees that a credit card issuer may require a consumer to pay with respect to an account, limiting fees to 25 percent of the credit limit in effect when the account is opened. Regulation Z currently states that this limitation applies prior to account opening and during the first year after account […]
Tag: Lending Compliance
RENEWING LOANS WITH FORCE PLACED INSURANCE
“Can we renew a loan which is covered by force placed insurance?” Variations on this question have come up several times in recent seminars I have conducted. The answer to the question is no. If a borrower refuses to obtain flood insurance coverage as a condition of obtaining a loan, the loan is deficient and may not be made. Force placement of coverage is designed for use at any time during the loan in uninsured […]
THREE-YEAR RIGHT TO RESCIND
Over the years many of you have heard me discuss the rescission rules contained in Regulation Z. I always explained that if the lender screws up and fails to give the notice, fails to give a timely notice, fails to give the correct notice, fails to properly complete the notice, fails to wait three days before distributing the form, fails to give timely and accurate TIL disclosures, or makes any one of several other errors […]
NEW FEDERAL REGISTRY RESOURCE CENTER OPENS
On April 2, 2012 the Nationwide Mortgage Licensing System & Registry opened a new Federal Registry Resource Center. Everything needed for Federal Registration is available in the new center, including all Quick Guides, instructions and reference materials that pertain to Federal Registration. The new Center is available at: https://fedregistry.nationwidelicensingsystem.org/Pages/default.aspx
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, […]