Archive

TRID AND DAYLIGHT SAVINGS TIME

Daylight Saving Time (DT) begins on March 12, 2017. What does that 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 need to remember to change the time designation used […]

REVISED SMALL ENTITY COMPLIANCE GUIDE FOR MORTGAGE SERVICING RULES

On November 30, 2016 the Consumer Financial Protection Bureau published an updated version of the Small Entity Compliance Guide entitled  Real Estate Settlement Procedures Act (Regulation X) and Truth In Lending Act (Regulation Z) Mortgage Servicing Rules. The Guide is updated to reflect the August 2016 Final Rule that makes significant changes to the servicing rules contained in both regulations. The August 2016 Final Rule changes impact all financial institutions. The impact on small servicers […]

EFFECTIVE DATE FOR FINAL SERVICING RULES ESTABLISHED

On October 19, 2016 the final Servicing Rules published by the Consumer Financial Protection Bureau on August 6, 2016 were finally published in the Federal Register. The final rule clarifies, revises, or amends provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; and prompt crediting and periodic statement requirements under Regulation Z’s servicing provisions. The final rule also addresses proper compliance regarding certain servicing requirements […]

FINAL REVISIONS TO SERVICING RULES

On August 4, 2016 the Consumer Financial Protection Bureau (CFPB) published revisions to rules for servicers that went into effect on January 10, 2014. The CFPB issued proposed amendments to those rules in November 2014, and the final rule adopts many of the proposed provisions. This final rule clarifies, revises, or amends provisions regarding: Force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; Prompt crediting and periodic […]

TRID PROPOSAL

“The Consumer Financial Protection Bureau has begun drafting a Notice of Proposed Rulemaking (NPRM) to make adjustments to the Know Before You Owe rule,” CFPB director Richard Cordray told industry trade groups in an April 28 letter. Cordray said he hopes the NPRM will be issued in late July. Well his “hopes” became reality late last week. On July 28 the CFPB Published a 293-page proposal. The proposal has a quick 82-day comment period, which […]