Archive

NEW INTEGRATED DISCLOSURES RELEASED

On October 20, 2013 the Consumer Financial Protection Bureau published the new rules for the integrated disclosures. The new rule is 1,888 pages long and is effective on August 1, 2015. The CFPB is not revising finance charge rules at this time. A copy of the new rule is available here.

KNOW BEFORE YOU OWE: MORTGAGES

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 […]

ESCROW EXEMPTION WINDOW REMAINS OPEN

Some creditors never wanted to play the escrow game. Section 1026.35(b)(2(iii) of Regulation Z creates an exemption from escrowing on first-lien higher-priced mortgage loans for certain creditors. The exemption originally required action by June 30, 2013. Some creditors that were eligible for the exemption missed the June 30th deadline and the opportunity for the exemption. A subsequent revision to Regulation Z has reopened the window of opportunity for taking advantage of the exemption until January […]

KNOW BEFORE YOU OWE

What happened to the new integrated disclosure rules that were supposed to be published in September? Several months ago the Consumer Financial Protection Bureau (CFPB) announced that publication of the new rules would occur in October. Now the CFPB has announced a field  hearing on Know Before You Owe: Mortgages on November 20, 2013 at 11:00 am EST. The meeting will be held in Boston. Past releases regarding the new integrated disclosures have referenced Know Before […]

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 […]