Archive

TIL/RESPA POSSIBILITIES

While the Consumer Financial Protection Bureau (CFPB) has been developing and testing the combined TIL/RESPA forms a number of issues have come to their attention. Following are a few items in their crosshairs: Many lenders and mortgage brokers provide consumers with preliminary estimates of loan terms and settlement costs that are not mandated by TILA or RESPA. The CFPB is considering whether to require that these preliminary estimates carry a disclaimer that tells the consumer […]

STATUS OF CFPB’s COMBINED MORTGAGE DISCLOSURES

Several months ago, the Consumer Financial Protection Bureau (CFPB) published in its blog two sample closing disclosures that combine final Truth in Lending (TIL) disclosures with HUD-1 disclosures. They requested that consumers and industry members compare two prototypes for the disclosures and vote on the preferred option. Now the CFPB is asking consumers and industry members to look specifically at how the new closing disclosure prototypes work with the application disclosure prototype, which was pretty […]

THE CFPB INHERITS REGULATION X

Congress enacted the Real Estate Settlement Procedures Act of 1974 (RESPA) based on findings that significant reforms in the real estate settlement process were needed to ensure that consumers are provided with greater and more timely information on the nature and costs of the residential real estate settlement process and are protected from unnecessarily high settlement charges caused by certain abusive practices that Congress found to have developed. In 1990, Congress amended RESPA by adding […]

CFPB – THE INHERITED REGULATIONS – PART II

On November 29th the Consumer Financial Protection Bureau (CFPB) published a notice and request for information about streamlining the inherited regulations. The “inherited regulations” include 14 existing consumer regulations that the CFPB inherited from other regulatory agencies on July 21, 2011, including, among others, Regulation Z (Truth in Lending) and Regulation X (RESPA). The inherited regulations are published in Chapter X of Title 12 of the Code of Federal Regulations. Following is the schedule of […]

CFPB – THE INHERITED REGULATIONS

On November 29th the Consumer Financial Protection Bureau (CFPB) published a notice and request for information about streamlining the inherited regulations. The “inherited regulations” include 14 existing consumer regulations, including, among others, Regulation Z (Truth in Lending) and Regulation X (RESPA), that the CFPB inherited from other regulatory agencies on July 21, 2011. The inherited regulations are published in Chapter X of Title 12 of the Code of Federal Regulations. On December 16, 2011 the […]