Recently the Consumer Financial Protection Bureau (CFPB) published an interim final rule that amends existing final servicing rules contained in Regulation X and Z. Comments will be accepted until November 22, 2013. The rule is effective January 10, 2014. The changes to changes routine is wearing thin, but these changes are helpful and do not significantly increase the compliance burden. Among other changes the amendments clarify the specific disclosures that must be provided before counseling […]
Tag: Truth in Lending
DILEMMA FOR ARMs WITH NO LOOK BACK PERIOD
Effective on January 10, 2014 Section 1026.20 of Regulation Z requires, when a rate change accompanied by a payment change occurs on an ARM, a notice to be sent to the consumer at least 60, but no more than 120, days before the first payment at the adjusted level is due. However a different timing rule (at least 25, but no more than 120, days before the first payment at the adjusted level is due) applies […]
EFFECTIVE DATE FOR NEW ARM NOTICES
Effective on January 10, 2014 § 1026.20 of Regulation Z requires that when a rate change accompanied by a payment change occurs on an ARM a notice must be sent to the consumer at least 60, but no more than 120, days before the first payment at the adjusted level is due (§ 1026.20(c)). An additional notice is required in connection with the initial interest rate adjustment provided to consumers. That notice must be provided at least […]
MORE FINAL REVISED RULES – REGULATIONS B, X, AND Z
On September 13 the Consumer Financial Protection Bureau published it latest revisions to final rules that were published last January. The 274-page final rule: Revises error resolution procedures and information requests (§§ 1024.35 and 1024.36), and loss mitigation (§ 1024.41). With respect to loss mitigation, two of the revisions concern the requirement in § 1024.41(b)(2)(i) that a servicer review a borrower’s loss mitigation application within five days and provide a notice to the borrower acknowledging […]
MOST RECENT CFPB SEMI-ANNUAL RULEMAKING AGENDA
Recently the Consumer Financial Protection Bureau (CFPB) published its most recent semiannual rulemaking agenda. There were no big surprises in the agenda. This article reviews three issues of concern. Integrated Disclosures and Finance Charge Rules – The biggest rules yet to be finalized are the new integrated disclosures. The disclosures include the loan estimate (that combines the early TIL disclosure and the good faith estimate) and the closing disclosure (that combines the final TIL disclosures […]