The Dodd-Frank Act requires the Consumer Financial Protection Bureau (CFPB) to combine Truth in Lending Act and the Real Estate Settlement Procedures Act disclosures. The CFPB began with the early disclosures (the combined early TIL and GFE). Now they are working on the closing disclosures (the combined TIL/HUD-1). Early disclosures – For most lenders the early TIL and GFE disclosures currently include four to six pages. The proposed combined form consists of two pages. The […]
Tag: RESPA
HUD ISSUES ITS FINAL RESPA RULE
On July 11, just ten days before its rule-writing authority transfers to the new Consumer Financial Protection Bureau, HUD published revisions to Regulation X. The revisions generally address issues already covered in the Frequently Asked Questions and the RESPA Roundup. HUD did not touch any of the really screwed up issues that continue to plague lenders around the nation. The major revisions are summarized: The lender is not permitted to charge, as a condition for […]
WHAT’S UP WITH ESCROWS
On February 23, 2011 the Federal Reserve Board issued a final rule and requested public comment on a second rule under Regulation Z to revise the escrow account requirements for certain home mortgage loans. The revisions to the regulation, which implements the Truth in Lending Act (TILA), are being made pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act. The final rule implements a provision of the Dodd-Frank Act that increases the annual […]
PENALTY FOR FAILURE TO DELIVER A TIMELY GFE
Apparently examiners have recently slammed a few lenders for the failure deliver a GFE or for the failure to provide the GFE within the required three business day period. The penalty examiners are imposing for this RESPA violation is a refund of all fees imposed in the transaction. Yes; you read that correctly, a refund of all fees. Some bankers are asking what happened to the 10% tolerance applicable to certain items on the GFE. […]
New RESPA Settlement Cost Booklet
Rumor: HUD has published a new Settlement Cost Booklet This rumor is true. The new booklet appeared on HUD’s website on July 15th. Rumor: We have to throw out our existing supply of booklets and start using the new booklet immediately. This rumor is false. You may use the versions of the booklet published in December 2009 or January 2010, or you may use the new booklet. When you exhaust your existing supply of booklets […]