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BUSINESS DAY – NEW REGULATION B APPRAISAL RULES

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 […]

CFPB PUBLISHES NEW REGULATION B APPRAISAL RULES

On January 18, 2013 the Consumer Financial Protection Bureau published a124-page final rule to amend Regulation B, which implements the Equal Credit Opportunity Act. The final rule revises rules for appraisals and other valuations that was enacted as part of the Dodd-Frank Act. The final rule is effective on January 18, 2014. For applications for credit secured by a first lien on a dwelling the new rule: Requires creditors to notify applicants within three business […]

CFPB PUBLISHES SEMI-ANNUAL AGENDA

Today the Consumer Financial Protection Bureau (CFPB) published it’s semiannual agenda as part of the Fall 2013 Unified Agenda of Federal Regulatory and Deregulatory Actions. The Agenda reflects antipathy actions during the period from October 1, 2012 to October 1, 2013. The next agenda will be published in spring 2013 and will update the agenda through October 1, 2013. According to the agenda the following final rules are expected in January 2013: Regulation X and […]

HOW UNEARNED DISCOUNT POINTS MAY RESULT IN FAIR LENDING VIOLATIONS

This is the third part of a five part series that explores issues related to discount points. The previous article explored UDAAP concerns resulting from unearned discount points. This article considers how unearned discount points may result in fair lending violations. Almost any lending practice may result in an disparate impact violation under the Equal Credit Opportunity Act (ECOA), as implemented by Regulation B, and the Fair Housing Act (FHA). Charging unearned discount points is […]

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 […]