On August 15, 2012 the Federal Reserve Board, the Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively, the Agencies) jointly proposed to amend Regulation Z, to implement a Dodd-Frank Act provision requiring appraisals for “higher-risk mortgages.” Comments are due on or before October 15, 2012. The 211-page proposed rule generally defines a “higher-risk mortgage” as a closed-end consumer […]
Tag: Truth in Lending
CFPB – TWO MORE MAJOR PROPOSED RULES AMEND TIL AND RESPA
On August 10 the Consumer Financial Protection Bureau (CFPB) published two significant sets of proposed rules to revise the Truth in Lending (TILA) and the Real Estate Settlement Procedures (RESPA) Acts. Both rules deal with provisions related to the servicing of mortgage loans. TILA/Regulation Z – The proposed amendments implement the Dodd-Frank Act provisions regarding mortgage loan servicing. Specifically, the proposal implements addresses rules related to: Initial rate adjustment notices for adjustable-rate mortgages (ARMs); Periodic […]
MORE REGULATION Z (TIL) AND REGULATION X (RESPA)
The biggest big news on Monday July 9, 2013 was the 1,099 page proposal to combine TIL and RESPA forms. The other big news on Monday was the 293 page proposal to amend the Truth in Lending Act by expanding the types of mortgage loans that are subject to the protections of the Home Ownership and Equity Protection Act of 1994 (HOEPA), by revising and expanding the triggers for coverage under HOEPA, and by imposing […]
OBSERVATIONS ON THE REGULATION Z PROPOSAL
“It’s only a proposal!” I can get carried away by big events like the 1,099 page proposal we got from the CFPB on Monday. The reminder that it is only a proposal helps keep me grounded It is also easy to get mad at the CFPB for the massive changes moving our way, but we got to remember that Congress is the big problem. Actually the CFPB is trying to take a few heroic actions […]
CFPB RELEASES COMBINED TIL/RESPA FORM PROPOSAL
Earlier today the Consumer Financial Protection Bureau (CFPB) published the first of three proposed revisions to Regulation Z that are expected this month. The 1,099 page release proposes model forms and new rules for mortgage loans. The proposal combines Truth in Lending and RESPA disclosures into a single document The comment period expires, for the most part, on November 6, 2012; however the comment period for rules on changes in the calculation of the finance […]