Today the Consumer Financial Protection Bureau (CFPB) updated us on the extensive process used to develop the new combined TIL/RESPA forms. There is no question about it, the CFPB did exhaustive work designing the new combined forms. I expect the forms will be clearer and much easier to use. But there is one simple fact that Congress and the regulators refuse to grasp – borrowers do not read disclosures and they do not shop for […]
Tag: Truth in Lending
A LITTLE TEASER FROM THE CFPB
Today the Consumer Financial Protection Bureau (CFPB) published the first part of a series of articles leading up to the publication of the combined Truth in Lending/RESPA disclosures. The first article looks at the origins of the Know Before You Owe project for simplifying mortgage disclosures. Tomorrow, the CFPB looks back at how the project unfolded. And then very soon, the CFPB will explain the long-awaited new proposed rule to make mortgage disclosures more effective […]
REGULATION Z – THE END OF THE WORLD AS WE KNOW IT
Over the next six months Regulation Z will undergo the most extensive revisions in its 43 year history. The rules will primarily impact mortgage loan rules, for both open-end and closed-end credit. For mortgage loan disclosures, it will be the end of the world as we know it and the beginning of a brave new world of Regulation Z. Following is a summary of each piece of the revision process. Ability to Repay– A final […]
CFPB DELAYS ABILITY TO REPAY RULE
On May 31st the Consumer Financial Protection Bureau (CFPB) announced that it is seeking additional public comment on new data and information that it has received in a rulemaking to require lenders to revise Regulation Z to assess consumers’ ability to repay mortgage loans before extending them credit. The latest comment period will close on July 9, 2012. The CFPB is a new agency so we need to cut them a little slack. What the […]
APPRAISAL SURVEY
Section 1026.41(f) of Regulation Z states, “The creditor and its agents shall compensate a fee appraiser for performing appraisal services at a rate that is customary and reasonable for comparable appraisal services performed in the geographic market of the property being appraised.” To assure the appraisal fee is “customary and reasonable” the creditor may either conduct its own appraiser survey or obtain a survey from a third party. In the past, several companies offer their […]