Archive

LIABILITY AFTER FORECLOSURE – THE SEQUEL

Last fall, we published a blog article that reviewed the intricacies of the “Liability after Foreclosure” disclosure.  Here we provide a quick update and add some valuable new information. As a refresher, the following disclosure appears in the Loan Estimate but only when the transaction is defined as a refinance: Liability after Foreclosure Taking this loan could end any state law protection you may currently have against liability for unpaid debt if your lender forecloses […]

TRID CORRECTION PUBLISHED BY CFPB

Can you believe that title?  The CFPB has actually published something for us in writing in the Federal Register that will clear up an item that has been a source of confusion since prior to the implementation of TRID. The publication in the Federal Register dated yesterday, February 10th, results in a correction to the Supplementary Information of the final rule to correct a typographical error.  Specifically, section 1026.19(e)(3)(iii) –  Variations Permitted for Certain Charges […]

EXAMINATION EXPECTATIONS – WHAT AGENCIES ARE ON BOARD WITH CFPB?

Last week, the FDIC provided the industry with a Financial Institution Letter (FIL 43-2015) to detail what financial institutions can expect in terms of initial examinations after the October 3rd TRID implementation date.  The first blog article in this series regarding TRID exam expectations can be found here. The Financial Institution Letter came after the CFPB released in mid-September the updated examination procedures the Bureau will rely on to complete initial exams.  In July, Director […]