As we recently reported, today is a big day for mortgage lenders. The Consumer Financial Protection Bureau (CFPB) is releasing the new integrated disclosures in conjunction with a field meeting scheduled at 11:00 a.m. in Boston. The new Loan Estimate form combines the good faith estimate and the early TIL disclosure. The new Closing disclosure combines the HUD-1 and the final TIL disclosure. The good news is that use of the new forms will not […]
Tag: Regulation X
HOMEOWNERSHIP COUNSELING ORGANIZATIONS LISTS
Section 1024.20(a)(1) of Regulation X requires lenders to provide the loan applicant with a written list of homeownership counseling organizations that provide relevant services in the loan applicant’s location. The rule is effective on January 10, 2014. On November 7, 2013 the Consumer Financial Protection Bureau (CFPB) issued a final rule and made available a tool that produces the appropriate list of counselors. A lender may use the CFPB tool or may develop its own […]
AMENDMENTS TO REGULATION X AND Z SERVICING RULES
Recently the Consumer Financial Protection Bureau (CFPB) published an interim final rule that amends existing final servicing rules contained in Regulation X and Z. Comments will be accepted until November 22, 2013. The rule is effective January 10, 2014. The changes to changes routine is wearing thin, but these changes are helpful and do not significantly increase the compliance burden. Among other changes the amendments clarify the specific disclosures that must be provided before counseling […]
MORE FINAL REVISED RULES – REGULATIONS B, X, AND Z
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 […]
NETTING AN ESCROW BALANCE AGAINST THE PAYOFF AMOUNT
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. […]