Archive

EXTENDED DATE FOR NEW MORTGAGE DISCLOSURES

On November 16, 2012 the Consumer Financial Protection Bureau (CFPB) announced that it will give creditors extra time to provide certain new disclosures required under the Dodd-Frank Wall Street Reform and Consumer Protection Act in order to allow a more seamless integration with other mortgage disclosures that have been proposed by the Bureau. The Dodd-Frank Act: Requires the CFPB to integrate certain disclosures from the Truth in Lending Act (TILA) and the Real Estate Settlement […]

MORE ON TESTING INTEGRATED MORTGAGE LOAN DISCLOSURES

Following our recent article about testing the integrated mortgage disclosure forms we received several inquiries requesting more information about the process, particularly about submitting a comment. This article responds to those requests. The Issue – The volume of changes from the Dodd-Frank Act that are currently unfolding is daunting. Over 2,400 pages of proposed regulations have been published in just the past two months alone. A huge bank can assign a team to the task of […]

YOUR ASSIGNMENT: TEST INTEGRATED MORTGAGE LOAN DISCLOSURES

The volume of changes from the Dodd-Frank Act that are currently unfolding is daunting. Based on the numerous complaints about the GFE and the HUD-1 I have fielded over the past 30 months, the issue of greatest concern may be the new integrated mortgage loan disclosures. The proposed rule for the Loan Estimate and Closing Disclosure covers 1,099 pages. Reading the proposal, gaining an understanding of the requirements, and trying your hand at completing the […]

CFPB – TWO MORE MAJOR PROPOSED RULES AMEND TIL AND RESPA

On August 10 the Consumer Financial Protection Bureau (CFPB) published two significant sets of proposed rules to revise the Truth in Lending (TILA) and the Real Estate Settlement Procedures (RESPA) Acts. Both rules deal with provisions related to the servicing of mortgage loans. TILA/Regulation Z – The proposed amendments implement the Dodd-Frank Act provisions regarding mortgage loan servicing.  Specifically, the proposal implements addresses rules related to: Initial rate adjustment notices for adjustable-rate mortgages (ARMs); Periodic […]

MORE REGULATION Z (TIL) AND REGULATION X (RESPA)

The biggest big news on Monday July 9, 2013 was the 1,099 page proposal to combine TIL and RESPA forms. The other big news on Monday was the 293 page proposal to amend the Truth in Lending Act by expanding the types of mortgage loans that are subject to the protections of the Home Ownership and Equity Protection Act of 1994 (HOEPA), by revising and expanding the triggers for coverage under HOEPA, and by imposing […]