On April 28, 2018 the Consumer Financial Protection Bureau (CFPB) finalized an amendment to its Truth in Lending/Real Estate Settlement Procedures Act Integrated Disclosures (TRID) that addresses when a creditor may compare charges paid by or imposed on the consumer to amounts disclosed on a Closing Disclosure, instead of a Loan Estimate, to determine if an estimated closing cost was disclosed in good faith. Under the current rule, circumstances may arise in which a cost […]
Tag: Truth in Lending
UPDATED RESPA AND TILA EXAMINATION PROCEDURES
On April 19, 2018 the Federal Reserve Board published a Consumer Affairs Letter (CA 18-3) regarding Revised Interagency Examination Procedures for Regulation X and Regulation Z. The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council recently developed the interagency examination procedures for the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA). The revised examination procedures supersede the examination procedures transmitted with CA Letter 15-6. The procedures […]
LAST MINUTE REVISIONS TO REGULATION Z SERVICING RULES
On March 6, 2018 the Consumer Financial Protection Bureau (CFPB) issued a final rule to help mortgage servicers communicate with certain borrowers facing bankruptcy. The revisions to Regulation Z give mortgage servicers more latitude in providing periodic statements to consumers entering or exiting bankruptcy, as required by the Bureau’s 2016 mortgage servicing rule. The 2016 mortgage servicing rule requires that servicers send modified periodic statements or coupon books to certain consumers in bankruptcy starting April 19, 2018. […]
TRID AND DAYLIGHT SAVINGS TIME
Daylight Saving Time (DT) begins on March 11, 2018 at 2:00 a.m.. It ends on November 4, 2018. What does DT have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in areas that observe DT […]
DISCOUNT POINTS
On November 28, the Federal Reserve Board (FRB) issued a consent order against Peoples Bank (Peoples), Lawrence, Kansas, for deceptive residential mortgage origination practices in violation of section 5 of the Federal Trade Commission Act. Apparently Peoples told certain borrowers that they were paying an additional amount for discount points that would lower the borrowers’ interest rate. In fact, many borrowers did not receive a reduced rate. The consent order requires Peoples to pay approximately […]