Archive

OBSERVATIONS ON THE REGULATION Z PROPOSAL

“It’s only a proposal!” I can get carried away by big events like the 1,099 page proposal we got from the CFPB on Monday. The reminder that it is only a proposal helps keep me grounded It is also easy to get mad at the CFPB for the massive changes moving our way, but we got to remember that Congress is the big problem. Actually the CFPB is trying to take a few heroic actions […]

CFPB RELEASES COMBINED TIL/RESPA FORM PROPOSAL

Earlier today the Consumer Financial Protection Bureau (CFPB) published the first of three proposed revisions to Regulation Z that are expected this month. The 1,099 page release proposes model forms and new rules for mortgage loans. The proposal combines Truth in Lending and RESPA disclosures into a single document The comment period expires, for the most part, on November 6, 2012; however the comment period for rules on changes in the calculation of the finance […]

CFPB’s LATEST COMMENTS ON THE NEW COMBINED FORMS

Today the Consumer Financial Protection Bureau (CFPB) updated us on the extensive process used to develop the new combined TIL/RESPA forms. There is no question about it, the CFPB did exhaustive work designing the new combined forms. I expect the forms will be clearer and much easier to use. But there is one simple fact that Congress and the regulators refuse to grasp – borrowers do not read disclosures and they do not shop for […]

A LITTLE TEASER FROM THE CFPB

Today the Consumer Financial Protection Bureau (CFPB) published the first part of a series of articles leading up to the publication of the combined Truth in Lending/RESPA disclosures. The first article looks at the origins of the Know Before You Owe project for simplifying mortgage disclosures. Tomorrow, the CFPB looks back at how the project unfolded. And then very soon, the CFPB will explain the long-awaited new proposed rule to make mortgage disclosures more effective […]

SERVICING RULES – PREVIEW

Recently the Consumer Financial Protection Bureau outlined major new rules that impact mortgage loan servicing. The rules, which revise the Truth in Lending Act and the Real Estate Settlement Procedures Act, are required by the Dodd-Frank Act. Under the rules servicers must: Provide periodic statements for all residential mortgage loans; Provide a new notice 6 months prior to interest rate reset on ARM loans; Provide notices and establish other requirements for force-placed insurance; Credit payments […]