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On September 13 the Consumer Financial Protection Bureau published it latest revisions to final rules that were published last January. The 274-page final rule: Revises error resolution procedures and information requests (§§ 1024.35 and 1024.36), and loss mitigation (§ 1024.41). With respect to loss mitigation, two of the revisions concern the requirement in § 1024.41(b)(2)(i) that a servicer review a borrower’s loss mitigation application within five days and provide a notice to the borrower acknowledging […]

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 […]

On June 24, 2013 the Consumer Financial Protection Bureau published proposed changes to several final rules originally published in January 2013. The proposal would: Provide procedures for obtaining follow-up information on loss-mitigation applications; Make it easier for servicers to offer short-term forbearance plans; Revise the definitions of “rural” and “underserved” and provide interim rules until the revised definitions are complete; Provide clarification about financing credit insurance; Clarify the definition of “loan originator;” Clarify the definition […]

Recently the Consumer Financial Protection Bureau (CFPB) published a bulletin (CFPB Bulletin 2013-02) that provides guidance on compliance with the fair lending requirements of the Equal Credit Opportunity Act (ECOA) and Regulation B for indirect auto lenders. The bulletin addresses practices that permit dealers to increase consumer interest rates and to compensate dealers with a share of the increased interest revenues. This guidance applies to all indirect auto lenders, including both depository institutions and nonbank […]

The appraisal rules contained in Regulation B were revised on January 18, 2013. The revisions are effective on January 18, 2014. Among other requirements, the revised regulation requires that: A copy of each appraisal or other written evaluation be provided to the applicant three business days prior to consummation; Not later than the third business day after the creditor receives the application it must provide the applicant with a notice regarding the right to receive […]