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PROPOSED REVISIONS TO HIGHER-PRICED MORTGAGE LOAN APPRAISAL RULES

Recently the Board of Governors of the Federal Reserve System; Bureau of Consumer Financial Protection; Federal Deposit Insurance Corporation; Federal Housing Finance Agency; National Credit Union Administration; and Office of the Comptroller of the Currency (collectively, the Agencies). proposed additional changes to the Higher-Priced Mortgage Loan appraisal rules that were published January 18, 2013. The comment period for the proposal ends on September  9, 2013. The January Rule requires creditors to obtain an appraisal or […]

REVISED REGULATION Z EXAMINATION PROCEDURES

Recently the federal financial institution regulatory agencies released updated Regulation Z Examination procedures. The revised interagency examination procedures  reflect amendments implementing revisions to the Truth in Lending Act under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) that:  (1) restrict mandatory arbitration agreements in mortgage loans; and (2) revise existing escrow requirements on first-lien higher-priced mortgage loans.  These amendments are effective with respect to transactions for which the creditor receives an application […]

CFPB PROPOSES CHANGES TO REGULATIONS B, X, AND Z

On June 24, 2013 the Consumer Financial Protection Bureau published proposed changes to several final rules originally published in January 2013. The proposal would: Provide procedures for obtaining follow-up information on loss-mitigation applications; Make it easier for servicers to offer short-term forbearance plans; Revise the definitions of “rural” and “underserved” and provide interim rules until the revised definitions are complete; Provide clarification about financing credit insurance; Clarify the definition of “loan originator;” Clarify the definition […]

CFPB PUBLISHES THE FINAL FINAL ABILITY-TO-REPAY AND QUALIFIED MORTGAGE STANDARDS

On May 29, 2013 the Consumer Financial Protection Bureau (CFPB) published a final2 rule to amend a final rule published in January 2013 that generally prohibits a creditor from making a mortgage loan unless the creditor determines that the consumer will have the ability to repay the loan.. The final2 rule provides an exemption to these requirements for creditors with certain designations, loans pursuant to certain programs, certain nonprofit creditors, and mortgage loans made in connection […]

CFPB PUBLISHES FINAL FINAL RULE AMENDING THE PROHIBITION ON FINANCING CREDIT INSURANCE PREMIUMS

On May 29, 2013 the Consumer Financial Protection Bureau (CFPB) published a final2 rule that amends Regulation Z to delay the June 1, 2013 effective date of a prohibition on creditors financing credit insurance premiums in connection with certain consumer credit transactions secured by a dwelling. The CFPB is delaying the effective date until January 10, 2014, to permit the Bureau to clarify, before the provision takes effect, its applicability to transactions other than those […]