New CFPB mortgage servicing rules present significant challenges for mortgage servicers

Size: px
Start display at page:

Download "New CFPB mortgage servicing rules present significant challenges for mortgage servicers"

Transcription

1 New CFPB mortgage servicing rules present significant challenges for mortgage servicers Prepared by: Jose Vivar, Director, McGladrey LLP , Michael Sher, Partner, McGladrey LLP , August 2013 Effective January 14, 2014, mortgage servicers will need to comply with new rules issued by the Consumer Financial Protection Bureau (CFPB). These rules amend Regulation Z, implementing the Truth in Lending Act (TILA); Regulation X, implementing the Real Estate Settlement Procedures Act (RESPA); and certain provisions of the Dodd-Frank Act. The challenge Implementation and compliance presents a challenge, because the mortgage servicing rules breadth will require new policies and procedures, system changes and training development and delivery. Ultimately, the biggest challenge is finding personnel who can effectively plan, design, oversee and implement the changes, while still fulfilling their normal responsibilities. The project s size and importance merits a comprehensive and focused effort. There is significant reputational, operational and financial risk at stake, as evidenced by the regulatory actions and adverse media coverage of mortgage servicers already subject to similar rules. Further, the effort needs to start now, if it hasn t already, in order to have everything tested and operational by January The rules The first step for mortgage servicers is to understand the requirements. These rules are extensive, covering nine major aspects of mortgage servicing: y Periodic billing statements y Interest rate adjustment notices for Adjustable Rate Mortgages (ARMs) y Payment crediting and payoff statements y Force-placed insurance y Error resolution and information requests y General servicing policies, procedures and requirements y Early intervention with delinquent borrowers y Continuity of contact with delinquent borrowers y Loan mitigation procedures

2 Following is a brief overview of the key rules in the nine major areas. Servicers should read the complete rules to gain a full understanding of the new requirements. Periodic billing statements The new rule prescribes the timing, form and content that servicers must provide in periodic billing statements. The rule requires that each periodic billing statement includes information on the amount due and explanation, past payment breakdown, transaction activity and information on partial payments, servicer contact, account specifics and delinquency, if the borrower is more than 45 days past due. These new rules apply to closed-end consumer loans secured by a residential dwelling, and do not apply to reverse mortgages, time-share plans or to fixed-rate loans for which the servicer provides a coupon book. With respect to coupon books, the following must be included; (i) amount due, (ii) account information, (iii) contact information, and (iv) notice that help is available by request, either by telephone, in writing or in person. It has to be noted that mortgage loans originated with an ACH payment option will be subjected to the new rules. Interest rate adjustment notices for ARMs There are a host of notice requirements: y Interest rate adjustments on ARMs have to be communicated at least 210 days, but not more than 240 days, prior to the first payment due after the rate first adjusts. y At least 60 days, but not more than 120 days, before payment at a new level, when a rate adjustment causes the payment to change. y ARMs with scheduled interest rate adjustments occurring every 60 days or more frequently, and ARMs originated prior to January 10, 2015, in which the interest rate and payment are based on an index available as of a date that is less than 45 days prior to the interest rate adjustment date notice, must be provided notice at least 25 days, but not more than 120 days, before the first payment at a new level is due. y Notice of an interest rate change must be provided at least 25 days before payment at a new level, as a result of interest rate change for ARMs, if the change occurs within 60 days of closing and the new rate disclosed at closing is an estimate. The new rules also apply to: (i) closed-end consumer loans secured by a residential dwelling in which the interest rate may change after closing, and (ii) ARMs that convert to a fixed-rate mortgage loan, if the conversion results in a payment change. Interest rate change notices do not apply to: (i) ARMs that have a term of one year or less, or to (ii) ARMs if the first payment change is due within 210 days after closing, provided the new interest rate disclosed at closing was not an estimate. Prompt payment crediting and payoff statements The new rule stipulates the timing of crediting and applying payments, and responding to payoff requests. Servicers must credit periodic payments on the day they are received. If a servicer receives a payment less than the amount due for a periodic payment, the payment may be held in a suspense account until the amount in the suspense account covers a periodic payment; then, the servicer must apply the funds to the consumer s account. A payment qualifies as a periodic payment, even if it is insufficient to cover late fees, other fees or repayment of corporate advances. 2

3 Servicers also have to provide an accurate payoff balance to a consumer within seven business days of receiving a written request from the borrower or party acting on behalf of the borrower. Force-placed insurance There are a variety of changes regarding force-placed insurance, including: (i) not assessing a force-placed insurance premium, unless the servicer has a reasonable basis to believe that the borrower has failed to maintain hazard insurance, and (ii) providing written notices before charging the borrower for force-placed insurance. Specific items have to be included in the first notice, and the second notice is similar to the first notice, except for the requirement of additional disclosures. A similar notice is required upon the renewal of force-placed insurance, except no second notice is required before assessing a force-placed insurance premium after 45 days from the date of the notice. Error resolution and information requests Requirements that servicers must meet when responding to written information requests or complaints about errors are set in the new rules. Servicers must comply with the error resolution procedures for a number of categories of covered errors, and may designate a specific address for borrowers to use for information requests or error complaints. Furthermore, servicers must: (i) acknowledge information requests and error complaints within five days, in addition to correcting and providing notice of correction, and (ii) provide information within 30 to 45 days. Formal tracking reports will need to be implemented company-wide to help monitor compliance, if not already, in order to manage this process and to provide evidence of compliance. General servicing policies, procedures, and requirements The new rules require servicers to establish policies and procedures, which have to take into account the size, scope and nature of the servicer s operations. The CFPB and other bank regulators will be able to supervise servicers within their jurisdiction to assure compliance with policies and procedures. However, there will not be a private right of action to enforce these provisions. Servicers will need to perform a gap analysis to determine which current processes and procedures need to change as a result of the new rules. Early intervention with delinquent borrowers Servicers have to make a good faith effort to establish contact with borrowers by the 36th day of their delinquency and must: (i) promptly inform the borrowers of their loss mitigation options, and (ii) provide the borrowers with written notice by the 45th day of a borrower s delinquency. This notice includes specific elements, and a servicer is not required to provide the written notice more than once in any 180-day period. Formalized tracking systems will need to be implemented to manage this process and provide evidence that the servicer is compliant. 3

4 Continuity of contact with delinquent borrowers Maintaining reasonable policies and procedures for providing delinquent borrowers assistance with loss mitigation options is required in the new rules. Such policies and procedures should ensure assignment of trained personnel to a delinquent borrower by the time of the required written notice, and ensure availability of personnel by phone to respond to borrower inquiries and to provide assistance to the borrower. Despite the CFPB and other bank regulators having the ability to supervise servicers to assure compliance with these requirements, there will not be a private right of action to enforce the provisions. As with other aspects of these rules, servicers will need to implement formalized tracking systems to manage continuity of contact with delinquent borrowers to provide evidence that they are in compliance. Loss mitigation procedures One objective of the new rules is to prevent dual tracking, whereby a servicer is simultaneously evaluating a consumer for loan modification, while also preparing to foreclose. The new rules establish specified loss mitigation procedures for mortgage loans secured by a borrower s principal residence, including: requiring the servicer to acknowledge receipt of applications in writing; and to provide information on the application s completeness, the borrower s options for alternative financing options and the time period to submit any missing information. The servicer has additional requirements upon receipt of a complete loan modification application, and has the duty to exercise reasonable diligence in evaluating all loss mitigation options available. If the borrower s loan modification is denied, the borrower must be given a notice stating why. Additionally, if a complete loan modification application is received 90 days or more before a foreclosure sale, the borrower must be given at least 14 days to accept or reject the loan modification offer. There is a right of public action for all of the provisions relating to loss mitigation. Additionally, the CFPB and other bank regulators can supervise servicers. Policies and procedures for managing the existing residential portfolio must be enhanced to reflect the requirements of early intervention with borrowers and loss mitigation rules. The new rules require careful legal interpretation, in order to avoid violation of certain rules. For example, notice of receipt of a completed loan modification application or notice of missing information is explicitly required when received 45 days or more before a foreclosure sale. However, it is always a good practice to communicate to the borrower missing information within a specified period. Policies and procedures should state that written communications should be sent to a borrower within a specified period acknowledging receipt of a completed loan modification application or providing a listing of missing information. Exemptions Not all mortgages servicers are subject to all of the new rules. General exemptions The 2013 amendments to RESPA generally apply to all closed-end, federally related mortgage loans, except for loans on property of 25 acres or more, business purpose loans, temporary financing, loans secured by vacant land and certain loan assumptions or conversions. Open-end mortgage loans are generally exempt, and servicers of reverse mortgages or servicers who are qualified lenders under the Farm Credit Act of 1971 are generally exempt from a number of rules. 4

5 Small servicer exemption The CFPB provided an exemption for small servicers for some of the new rules. Small servicers are defined as those servicing 5,000 or fewer mortgage loans, and servicing only mortgage loans that the servicer or an affiliate owns or originated. However, this exemption only applies to: (i) periodic billing statements, (ii) general servicing policies, (iii) procedures and requirements, (iv) early intervention with delinquent borrowers and (v) continuity of contact with delinquent borrowers. Small servicers are required to comply with several portions of the loss mitigation provisions, and are not exempt from rules pertaining to interest rate adjustment notices, payment crediting and payoff statements, force-placed insurance (except as noted above), error resolution and information requests and loss mitigation procedures. Achieving compliance After having gained an understanding of the new requirements, it is prudent to perform an operation-wide assessment that identifies the people, processes and technology involved in each of the affected operational areas. An evaluation should include the following areas of your operations: y IT systems; to determine what changes will have to be made, in order to meet the reporting and other demands of the new rules y Business operations; to determine how to best design and document procedures that will allow them to perform compliance with the new rule effectively and efficiently y Training; to get people up to speed with new requirements and changes in procedures and systems Some questions to keep in mind as you perform your assessment: y Have you quantified the number of mortgage loans serviced, including estimating loans expected to be serviced effective January 2014? y Do you outsource some of the activities, such as monthly loan statements? Are third-party vendors ready to comply with the requirements of the above rules? y Have you quantified the manpower required to implement and comply with the above rules? Do you need additional personnel to design and implement a plan? Do you need additional personnel to maintain compliance with the new rules after implementation? Do you have the resources to design and present effective training for your personnel? The next step is to develop an implementation plan, including the following considerations: y Have you performed a gap analysis to determine what processes and procedures need to change as a result of the new rules? Do your policies and procedures reflect reality? y Has the plan been approved by senior management and the board (or similar oversight functions), as appropriate? y Has the plan been developed in consultation with or reviewed by key stakeholders, such as legal, risk, compliance and information technology? y Do you have a capable person with availability to champion the implementation plan? 5

6 y Does the plan contain key milestones, dates for completion of required steps for compliance and progress reports? How are you monitoring progress, such as through periodic reporting? Who monitors progress and keeps tasks on track? y Does the plan include an internal audit review? Have testing procedures been defined? How are results and progress tracked? y Does the plan identify the responsible parties for developing the plan, ensuring adherence to the plan, and maintaining future compliance? Is progress reported to senior management or the board (or similar oversight functions), as applicable? y Is your plan on schedule? If not, has the deviation from schedule been approved by the board, senior management or similar oversight function, as appropriate, and discussed with regulators? Are all aspects of your plan scheduled to be complete prior to the rule effective dates? y Have you discussed your implementation plan with regulators and compliance counsel, as applicable? Have discussions with regulators resulted in any changes to your implementation plan? y Do you have contracts with any third parties related to mortgage activities? If so, have you discussed and evaluated their implementation plan? Do you have a back-up plan, should the vendor not fully implement the necessary changes prior to the effective dates? A sound and well-executed implementation plan should result in a relatively orderly and effective incorporation of the new rules into your day-to-day business operations. Summary As you can appreciate, these are substantial new rules that will have an impact across your organization, and will expose you to new risks. The new rules will require effective and efficient implementation, as well as a planned and coordinated effort. McGladrey can relieve much of the strain by helping you develop an implementation and compliance plan, and once implemented, we make sure that compliance with the new servicing standards is being maintained. Our services can range from high-level guidance and facilitation to detailed planning and design. We can fill the manpower gap necessary to achieve the comprehensive and focused effort This document contains general information, may be based on authorities that are subject to change, and is not a substitute for professional advice or services. This document does not constitute assurance, tax, consulting, business, financial, investment, legal or other professional advice, and you should consult a qualified professional advisor before taking any action based on the information herein. McGladrey LLP, its affiliates and related entities are not responsible for any loss resulting from or relating to reliance on this document by any person. McGladrey LLP is an Iowa limited liability partnership and the U.S. member firm of RSM International, a global network of independent accounting, tax and consulting firms. The member firms of RSM International collaborate to provide services to global clients, but are separate and distinct legal entities that cannot obligate each other. Each member firm is responsible only for its own acts and omissions, and not those of any other party. McGladrey, the McGladrey logo, the McGladrey Classic logo, The power of being understood, Power comes from being understood, and Experience the power of being understood are registered trademarks of McGladrey LLP McGladrey LLP. All Rights Reserved. 6

The CFPB Finalizes New Mortgage Servicing Rules

The CFPB Finalizes New Mortgage Servicing Rules A DV I S O RY April 2013 The CFPB Finalizes New Mortgage Servicing Rules On January 17, 2013, the Consumer Financial Protection Bureau (CFPB) finalized rules implementing the mortgage loan servicing requirements

More information

Summary of Mortgage Servicing Rules

Summary of Mortgage Servicing Rules February 12, 2013 Summary of Mortgage Servicing Rules The Consumer Financial Protection Bureau (CFPB) released its final rules on mortgage loan servicing on January 17, 2013. These new national standards

More information

CFPB Mortgage Servicing Rules Overview

CFPB Mortgage Servicing Rules Overview CFPB Mortgage Servicing Rules Overview For additional information, visit www.consumerfinance.gov/regulations Note: This document was used in support of a live discussion. As such, it does not necessarily

More information

Regulatory Practice Letter September 2012 RPL 12-17

Regulatory Practice Letter September 2012 RPL 12-17 Regulatory Practice Letter September 2012 RPL 12-17 Mortgage Servicing Standards - CFPB Proposed Rule Executive Summary The Bureau of Consumer Financial Protection ( CFBP or Bureau ) released two proposed

More information

What mortgage servicing rules apply to me? Sorting out the scope and impact of the new mortgage servicing regulations

What mortgage servicing rules apply to me? Sorting out the scope and impact of the new mortgage servicing regulations What mortgage servicing rules apply to me? Sorting out the scope and impact of the new mortgage servicing regulations Prepared by: Jose Vivar, Director, McGladrey LLP 312.634.4394, jose.vivar@mcgladrey.com

More information

Bankruptcy - What is a CFPB Mortgage Servicer and How Does it Work?

Bankruptcy - What is a CFPB Mortgage Servicer and How Does it Work? Impact of the CFPB Mortgage Servicing Rules on Your Bankruptcy Practice Thomas E. Hoffman John Rao National Consumer Law Center 2013 CFPB Mortgage Servicing Rules Dodd-Frank Act of 2010 amended RESPA and

More information

ESCROW REQUIREMENTS UNDER TILA

ESCROW REQUIREMENTS UNDER TILA Overview Escrow Requirements Reg. Z High Cost Mortgage and Counseling - Reg. Z & X Ability to Repay & Qualified Mortgages Reg. Z & X Mortgage Servicing Reg. Z & X Loan Originator Compensation Reg. Z Copies

More information

CFPB Proposes Comprehensive Mortgage Servicing Regulations

CFPB Proposes Comprehensive Mortgage Servicing Regulations August 2012 CFPB Proposes Comprehensive Mortgage Servicing Regulations On August 9, 2012, the Consumer Financial Protection Bureau (CFPB) issued two notices of proposed rulemaking (NPRs) 1 implementing

More information

REGULATORY ALERT NATIONAL CREDIT UNION ADMINISTRATION 1775 DUKE STREET, ALEXANDRIA, VA 22314. DATE: January 2014 NO.: 14-RA-04

REGULATORY ALERT NATIONAL CREDIT UNION ADMINISTRATION 1775 DUKE STREET, ALEXANDRIA, VA 22314. DATE: January 2014 NO.: 14-RA-04 REGULATORY ALERT NATIONAL CREDIT UNION ADMINISTRATION 1775 DUKE STREET, ALEXANDRIA, VA 22314 DATE: January 2014 NO.: 14-RA-04 TO: SUBJECT: ENCL: Federally Insured Credit Unions Mortgage Servicing Requirements

More information

How To Serve A Mortgage In The United States

How To Serve A Mortgage In The United States Break Out Session: Mortgage Loan Servicing and Administration 2 Agenda Mortgage Servicing Rules (Real Estate Settlement Procedures Act [RESPA] and Truth in Lending Act [TILA]) Effective Date: Applications

More information

Regulatory Practice Letter January 2014 RPL 14-03

Regulatory Practice Letter January 2014 RPL 14-03 Regulatory Practice Letter January 2014 RPL 14-03 CFPB Nonbank Supervision of Student Loan Servicers Final Rule CFPB Student Loan Ombudsman - Annual Report Executive Summary Effective March 1, 2014, the

More information

2013 Real Estate Settlement Procedures Act (Regulation X) and Truth in Lending Act (Regulation Z) Mortgage Servicing Final Rules

2013 Real Estate Settlement Procedures Act (Regulation X) and Truth in Lending Act (Regulation Z) Mortgage Servicing Final Rules JANUARY 8, 2014 2013 Real Estate Settlement Procedures Act (Regulation X) and Truth in Lending Act (Regulation Z) Mortgage Servicing Final Rules SMALL ENTITY COMPLIANCE GUIDE 1 Version Log The Bureau updates

More information

CFPB Mortgage Servicing Standards

CFPB Mortgage Servicing Standards www.pwc.com/consumerfinance www.pwcregulatory.com CFPB Mortgage Servicing Standards An analysis of the Consumer Financial Protection Bureau s Real Estate Settlement Procedures Act (Regulation X) and Truth

More information

RESPA and TILA Mortgage Servicing Final Rules

RESPA and TILA Mortgage Servicing Final Rules This summary is provided by the Minnesota Credit Union Network for informational purposes only, and is intended to provide credit unions with the general regulatory requirements and effective dates for

More information

New Mortgage Rules Update

New Mortgage Rules Update New Mortgage Rules Update 1 OBJECTIVES To provide information regarding the new mortgage rules, in particular: Ability-to-Repay/Qualified Mortgages; Mortgage Loan Origination Compensation; High-Cost Loans

More information

REGULATORY ALERT NATIONAL CREDIT UNION ADMINISTRATION 1775 DUKE STREET, ALEXANDRIA, VA 22314. DATE: January 2014 NO.: 14-RA-03

REGULATORY ALERT NATIONAL CREDIT UNION ADMINISTRATION 1775 DUKE STREET, ALEXANDRIA, VA 22314. DATE: January 2014 NO.: 14-RA-03 REGULATORY ALERT NATIONAL CREDIT UNION ADMINISTRATION 1775 DUKE STREET, ALEXANDRIA, VA 22314 DATE: January 2014 NO.: 14-RA-03 TO: SUBJECT: ENCL: ACTION: Federally Insured Credit Unions Mortgage Servicing

More information

2013 Real Estate Settlement Procedures Act (Regulation X) and Truth in Lending Act (Regulation Z) Mortgage Servicing Final Rules

2013 Real Estate Settlement Procedures Act (Regulation X) and Truth in Lending Act (Regulation Z) Mortgage Servicing Final Rules JUNE 7, 2013 2013 Real Estate Settlement Procedures Act (Regulation X) and Truth in Lending Act (Regulation Z) Mortgage Servicing Final Rules SMALL ENTITY COMPLIANCE GUIDE 1 Please refer to our proposed

More information

CFPB s New Force-Placed Insurance Procedures

CFPB s New Force-Placed Insurance Procedures CFPB s New Force-Placed Insurance Procedures The Dodd-Frank Act amended Section 6 of the Real Estate Settlement Procedures Act of 1974 ( RESPA ) to provide that a servicer of a federally related mortgage

More information

CUNA s SUMMARY OF THE CFPB s MORTGAGE LENDING RULES Spring 2013

CUNA s SUMMARY OF THE CFPB s MORTGAGE LENDING RULES Spring 2013 MANDATORY ESCROW ACCOUNTS Effective: June 1, 2013 REGULATION Requires escrow accounts be maintained for five years (rather than the current one year) for higher-priced mortgage loans. A higher-priced mortgage

More information

Mortgage Servicing: Loss Mitigation (12 CFR 1024.41)

Mortgage Servicing: Loss Mitigation (12 CFR 1024.41) Mortgage Servicing: Loss Mitigation (12 CFR 1024.41) The Consumer Financial Protection Bureau s (CFPB) new mortgage servicing rule includes requirements and restrictions relating to communicating with

More information

Student Loan Servicing and the CFPB

Student Loan Servicing and the CFPB Regulatory Practice Letter April 2013 RPL 13-09 CFPB Nonbank Supervision Larger Participants for Student Loan Servicing Proposed Rule Executive Summary The Bureau of Consumer Financial Protection (CFPB

More information

The New Mortgage Servicing Rules. FMS East Coast Regional Conference September 17, 2013

The New Mortgage Servicing Rules. FMS East Coast Regional Conference September 17, 2013 The New Mortgage Servicing Rules FMS East Coast Regional Conference September 17, 2013 What are the new Mortgage Servicing Rules? Ability to Repay/Qualified Mortgage Rule 2013 HOEPA Rule Loan Originator

More information

Managing specialty finance compliance requirements with a compliance management system

Managing specialty finance compliance requirements with a compliance management system Managing specialty finance compliance requirements with a compliance management system Prepared by: Andrew Amrine, Supervisor, RSM US LLP andrew.amrine@rsmus.com, +1 253 382 2239 September 2013 For over

More information

CFPB Mortgage Servicing Standards

CFPB Mortgage Servicing Standards PwC s CFPB Mortgage Servicing Standards Perspectives Issue 5/October 2013 CFPB Mortgage Servicing Standards Understanding periodic statement rules Introduction This represents the fifth in a series of

More information

Regulatory Practice Letter February 2013 RPL 13-07

Regulatory Practice Letter February 2013 RPL 13-07 Regulatory Practice Letter February 2013 RPL 13-07 High Cost Mortgages and Homeownership Counseling; Escrow Requirements - CFPB Final Rules Executive Summary The Bureau of Consumer Financial Protection

More information

Summary of the proposed changes to the Mortgage Servicing Rules. The Consumer Financial Protection Bureau is proposing several amendments to the

Summary of the proposed changes to the Mortgage Servicing Rules. The Consumer Financial Protection Bureau is proposing several amendments to the Summary of the proposed changes to the Mortgage Servicing Rules The Consumer Financial Protection Bureau is proposing several amendments to the Bureau s Mortgage Servicing Rules under Regulation X, which

More information

Changes in Mortgage Regulation in 2013 Katie Wechsler December, 2012

Changes in Mortgage Regulation in 2013 Katie Wechsler December, 2012 Changes in Mortgage Regulation in 2013 Katie Wechsler December, 2012 In 2011 and 2012 the Federal banking agencies proposed several regulations to the mortgage industry, none of which have been finalized,

More information

Regulatory Practice Letter July 2013 RPL 13-17

Regulatory Practice Letter July 2013 RPL 13-17 Regulatory Practice Letter July 2013 RPL 13-17 CPFB Finalizes Additional Amendments to Rules Governing Ability-to Repay and Mortgage Servicing Standards Executive Summary The Bureau of Consumer Financial

More information

Help For Struggling Borrowers

Help For Struggling Borrowers DECEMBER 18, 2013 Help For Struggling Borrowers A guide to the mortgage servicing rules effective on January 10, 2014 Table of contents Introduction... 7 1. Applying for loss mitigation... 10 1.1 Introduction...

More information

Compliance Bulletin and Policy Guidance: Mortgage Servicing Transfers

Compliance Bulletin and Policy Guidance: Mortgage Servicing Transfers 1700 G Street, N.W., Washington, DC 20552 Bulletin 2014-01 Date: August 19, 2014 Subject: Compliance Bulletin and Policy Guidance: Mortgage Servicing Transfers The Bureau of Consumer Financial Protection

More information

Real Estate Settlement Procedures Act 1

Real Estate Settlement Procedures Act 1 Real Estate Settlement Procedures Act 1 Examination Objectives To determine if the financial institution has established policies and procedures to ensure compliance with the Real Estate Settlement Procedures

More information

Wall Street Reform and Consumer Financial Protection Act of 2010

Wall Street Reform and Consumer Financial Protection Act of 2010 Wall Street Reform and Consumer Financial Protection Act of 2010 Mortgage Servicing Issues February 4, 2011 Presented by Joseph Gabai 2010 Morrison & Foerster LLP All Rights Reserved mofo.com Financial

More information

FRESH. Agenda. Credit Union Integrated Mortgage Disclosures Are you Prepared?

FRESH. Agenda. Credit Union Integrated Mortgage Disclosures Are you Prepared? MCUL & Affiliates 2015 Annual Convention and Exposition Credit Union Integrated Mortgage Disclosures Are you Prepared? Glory LeDu Thursday, June 4, 2015 2:00 p.m. Sponsored by: FRESH Ideas to Reinvent

More information

Qualified Mortgage Rule After 6 Months

Qualified Mortgage Rule After 6 Months Latest Developments Under TILA and RESPA Attorney David Pelletier dpelletier@axley.com 608.260.2495 Attorney Kevin D. Trost ktrost@axley.com 608.283.6747 WISCONSIN BANKING LAW UPDATE Community Bankers

More information

CFPB Issues Much Anticipated Final Rules: Ability to Repay, Qualified Mortgages, Escrow Requirements and Homeownership Counseling

CFPB Issues Much Anticipated Final Rules: Ability to Repay, Qualified Mortgages, Escrow Requirements and Homeownership Counseling CFPB Issues Much Anticipated Final Rules: Ability to Repay, Qualified Mortgages, Escrow Requirements and Homeownership Counseling The Consumer Financial Protection Bureau ( CFPB ) issued their much anticipated

More information

CLARIFICATION OF MAJOR CHANGES. Integrated Mortgage Disclosures

CLARIFICATION OF MAJOR CHANGES. Integrated Mortgage Disclosures CLARIFICATION OF MAJOR CHANGES Integrated Mortgage Disclosures One of the mortgage industry s most anticipated provisions of the Dodd-Frank Act has been the integration of the Truth-in-Lending Act (TILA)

More information

CFPB Proposes New Mortgage Disclosure Rules

CFPB Proposes New Mortgage Disclosure Rules A DV I S O RY July 2012 On July 9, 2012, the Bureau of Consumer Financial Protection (CFPB) issued a proposed rule on mortgage disclosures (Proposed Rule) implementing requirements of the Dodd-Frank Wall

More information

Introduction. The new rules and forms take effect October 3 rd, 2015 for all loan applications submitted on or after that date.

Introduction. The new rules and forms take effect October 3 rd, 2015 for all loan applications submitted on or after that date. Introduction The new rules and forms take effect October 3 rd, 2015 for all loan applications submitted on or after that date. Phased-in approach: Continue to close out loans in the lender s pipeline using

More information

How To Write A Disclosure Form

How To Write A Disclosure Form Office of Consumer Protection Truth-In-Lending Real Estate Settlement Procedures Act Integrated Disclosures Webinar February 11, 2015 The information contained in this presentation is for informational

More information

Vendor Risk Management in the New Regulatory Environment. kpmg.com

Vendor Risk Management in the New Regulatory Environment. kpmg.com Vendor Risk Management in the New Regulatory Environment kpmg.com Vendor Risk Management in the New Regulatory Environment 2 Vendor Risk Management in the New Regulatory Environment Background Regulators

More information

Homeownership Counseling (12 CFR 1024.20)

Homeownership Counseling (12 CFR 1024.20) (12 CFR 1024.20) The Consumer Financial Protection Bureau s (CFPB) new mortgage rules include new requirements for providing federally-related mortgage loan applicants with a list of homeownership counseling

More information

Regulatory Practice Letter February 2014 RPL 14-05

Regulatory Practice Letter February 2014 RPL 14-05 Regulatory Practice Letter February 2014 RPL 14-05 CFPB Nonbank Supervision of International Money Transfer Providers Proposed Rule Executive Summary The Consumer Financial Protection Bureau (CFPB or Bureau)

More information

CUNA s COMPLIANCE HIGHLIGHTS

CUNA s COMPLIANCE HIGHLIGHTS CUNA s COMPLIANCE HIGHLIGHTS TILA/RESPA INTEGRATED MORTGAGE DISCLOSURES For more than 30 years, Federal law has required lenders to provide two different disclosure forms to consumers applying for a mortgage.

More information

CFPB Mortgage Servicing Transfers

CFPB Mortgage Servicing Transfers PwC s CFPB Mortgage Servicing Standards Perspectives Issue 9/October 2014 CFPB Mortgage Servicing Transfers Mortgage Servicing Transfer Bulletin: The revised CFPB guidelines should be a key chapter in

More information

New Servicing Rules under Regulation Z Periodic Statements & Adjustable Rate Mortgages Notices

New Servicing Rules under Regulation Z Periodic Statements & Adjustable Rate Mortgages Notices New Servicing Rules under Regulation Z Periodic Statements & Adjustable Rate Mortgages Notices FIS Regulatory Advisory Services www.fisregulatoryservices.com New Servicing i Rules under Regulation Z Periodic

More information

Know Before You Owe. TILA-RESPA Integrated Disclosure (TRID) Rule

Know Before You Owe. TILA-RESPA Integrated Disclosure (TRID) Rule Know Before You Owe TILA-RESPA Integrated Disclosure (TRID) Rule Background of CFPB The Consumer Financial Protection Bureau (CFPB) was established in 2010 under the Dodd-Frank Act Directed to publish

More information

TILA-RESPA Integrated Disclosure Rule

TILA-RESPA Integrated Disclosure Rule TILA-RESPA Integrated Disclosure Rule May 13, 2015 Joseph J. Reilly Partner Benjamin K. Olson Partner 1 Key Changes Effective for applications received by the creditor or mortgage broker on or after August

More information

TRUSTED INTELLIGENCE 1

TRUSTED INTELLIGENCE 1 TRUSTED INTELLIGENCE 1 POINT OF VIEW CFPB Know Before You Owe 2 Background The Consumer Financial Protection Bureau (CFPB) established new disclosure rules that become effective on mortgage applications

More information

Examination Procedures

Examination Procedures Exam Date: Exam ID No. Prepared By: After completing the risk assessment and Reviewer: examination scoping, examiners should use these Docket #: procedures, in conjunction with the compliance Entity Name:

More information

The Other Side of CFPB Compliance

The Other Side of CFPB Compliance The Other Side of CFPB Compliance Strengthening your compliance program via vendor management Legal Disclaimer This information is for the use of attendees only. Any distribution, reproduction, copying

More information

January 2013 CFPB Mortgage Rules: Charts Detailing Coverage of Transactions March 2013

January 2013 CFPB Mortgage Rules: Charts Detailing Coverage of Transactions March 2013 January 2013 CFPB Mortgage s: Charts Detailing Coverage of Transactions March 2013 2013 Morrison & Foerster LLP All Rights Reserved mofo.com In January 2013, the Consumer Financial Protection Bureau (CFPB)

More information

General Resources CFPB Resources ALTA Best Practices Closing Insight Notaries Business & Commercial Loans Foreign Consumers

General Resources CFPB Resources ALTA Best Practices Closing Insight Notaries Business & Commercial Loans Foreign Consumers Remember, a knowing or reckless violation of TRID, even if done under instructions from the lender, may result in penalties of up to $1 million a day per violation against the individual settlement agent.

More information

Single-Family Legal Essentials: CFPB Rules. Part 1

Single-Family Legal Essentials: CFPB Rules. Part 1 Single-Family Legal Essentials: CFPB Rules Part 1 2 Introduction & Background Dodd-Frank Act Rulemaking Mandate Established CFPB and transferred authority over TILA, RESPA, and other consumer financial

More information

New Regulations and Mortgage Document Management: What it Means for Mortgage Servicers

New Regulations and Mortgage Document Management: What it Means for Mortgage Servicers New Regulations and Mortgage Document Management: What it Means for Mortgage Servicers CT Representation Services New Regulations and Mortgage Document Management: What it Means for Mortgage Servicers

More information

2015 Fidelity National Title Group

2015 Fidelity National Title Group Five Things You Need to Know Before August 2015 WHAT IS THE CFPB? THE NEW LINGO Dodd-Frank Act --Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 CFPB Consumer Financial Protection Bureau

More information

Financial Services Update June 11, 2013

Financial Services Update June 11, 2013 Financial Services Update June 11, 2013 HIGHLIGHTS Federal Regulatory Developments: CFPB Amends Examination Manual State Regulatory Developments: Texas Proposes Constitutional Amendment Regarding Reverse

More information

Loss Mitigation Procedures and Foreclosure Hurdles

Loss Mitigation Procedures and Foreclosure Hurdles Loss Mitigation Procedures and Foreclosure Hurdles Attorney David Pelletier Axley Brynelson, LLP dpelletier@axley.com 608.260.2495 www.axley.com What does the loss mitigation rule require? Rule does not

More information

Policy Guidance on Supervisory and Enforcement Considerations Relevant to Mortgage

Policy Guidance on Supervisory and Enforcement Considerations Relevant to Mortgage BILLING CODE: 4810-AM-P BUREAU OF CONSUMER FINANCIAL PROTECTION Policy Guidance on Supervisory and Enforcement Considerations Relevant to Mortgage Brokers Transitioning to Mini-Correspondent Lenders AGENCY:

More information

PROPOSED REGULATION OF THE COMISSIONER OF MORTGAGE LENDING. LCB File No. R091-10

PROPOSED REGULATION OF THE COMISSIONER OF MORTGAGE LENDING. LCB File No. R091-10 PROPOSED REGULATION OF THE COMISSIONER OF MORTGAGE LENDING LCB File No. R091-10 NRS 645B MORTGAGE BROKERS EXPLANATION Matter in italics is new; matter in brackets [omitted material] is material to be omitted.

More information

Important Information Regarding TILA-RESPA Integrated Disclosure (TRID) Rule

Important Information Regarding TILA-RESPA Integrated Disclosure (TRID) Rule Important Information Regarding TILA-RESPA Integrated Disclosure (TRID) Rule Notice to students: If your course contains information on the Truth in Lending Act (TILA) and the Real Estate Settlement Procedure

More information

CONFERENCE OF STATE BANK SUPERVISORS AMERICAN ASSOCIATION OF RESIDENTIAL MORTGAGE REGULATORS NATIONAL ASSOCIATION OF CONSUMER CREDIT ADMINISTRATORS

CONFERENCE OF STATE BANK SUPERVISORS AMERICAN ASSOCIATION OF RESIDENTIAL MORTGAGE REGULATORS NATIONAL ASSOCIATION OF CONSUMER CREDIT ADMINISTRATORS CONFERENCE OF STATE BANK SUPERVISORS AMERICAN ASSOCIATION OF RESIDENTIAL MORTGAGE REGULATORS NATIONAL ASSOCIATION OF CONSUMER CREDIT ADMINISTRATORS STATEMENT ON SUBPRIME MORTGAGE LENDING I. INTRODUCTION

More information

TRID Survival Guide: Consumer Edition

TRID Survival Guide: Consumer Edition TRID Survival Guide: Consumer Edition What you need to know about the TILA-RESPA Integrated Closing Disclosures. NFM Lending NMLS # 2893 Toll-Free: 1-888-233-0092 www.nfmlending.com Introduction NFM Lending

More information

CONFERENCE OF STATE BANK SUPERVISORS AMERICAN ASSOCIATION OF RESIDENTIAL MORTGAGE REGULATORS NATIONAL ASSOCIATION OF CONSUMER CREDIT ADMINISTRATORS

CONFERENCE OF STATE BANK SUPERVISORS AMERICAN ASSOCIATION OF RESIDENTIAL MORTGAGE REGULATORS NATIONAL ASSOCIATION OF CONSUMER CREDIT ADMINISTRATORS CONFERENCE OF STATE BANK SUPERVISORS AMERICAN ASSOCIATION OF RESIDENTIAL MORTGAGE REGULATORS NATIONAL ASSOCIATION OF CONSUMER CREDIT ADMINISTRATORS STATEMENT ON SUBPRIME MORTGAGE LENDING I. INTRODUCTION

More information

Summary of Content Changes 2015.2 Update June 2015

Summary of Content Changes 2015.2 Update June 2015 Summary of Content Changes 2015.2 Update June 2015 General Notes In this policy release, we are moving forward with the policy revisions associated with the Truth in Lending Act (TILA) and Real Estate

More information

Income Verification Asset Verification Property Documentation

Income Verification Asset Verification Property Documentation Independence Title Are you buying or selling a home after October 3, 2015? Nationwide the mortgage lending industry (creditors) will face a big change beginning October 3rd of this year. Here are the 3

More information

NORTH AMERICAN TITLE COMPANY Like Clockwork. www.nat.com/cfpb

NORTH AMERICAN TITLE COMPANY Like Clockwork. www.nat.com/cfpb NORTH AMERICAN TITLE COMPANY Like Clockwork www.nat.com/cfpb UNDERSTANDING THE NEW LOAN ESTIMATE AND CLOSING DISCLOSURE FORMS American Title, we want to make sure all of our customers have the information

More information

Any business relationship between a bank and another entity, by contract or otherwise

Any business relationship between a bank and another entity, by contract or otherwise An Overview for Bank Directors Managing the Third Party Relationship Patrick Neuman Boardman & Clark LLP Madison, Wisconsin Any business relationship between a bank and another entity, by contract or otherwise

More information

CHAPTER 454M MORTGAGE SERVICERS

CHAPTER 454M MORTGAGE SERVICERS CHAPTER 454M MORTGAGE SERVICERS SECTION 454M-1 Definitions 454M-2 License required 454M-2.5 Unlicensed foreclosure actions voided 454M-3 Exemptions 454M-4 License; fees; renewals; voluntary surrender of

More information

New Loan Origination and Mortgage Servicing Rules

New Loan Origination and Mortgage Servicing Rules 5/15/ New Loan Origination and Mortgage Servicing Rules Personal Finance Seminar for Professionals University of Maryland Extension Presenter: Diane Cipollone, Esq. Director of Training National Fair Housing

More information

Early Summary of Ability to Repay and Qualified Mortgage Rules under Dodd-Frank Wall Street Reform and Consumer Protection Act.

Early Summary of Ability to Repay and Qualified Mortgage Rules under Dodd-Frank Wall Street Reform and Consumer Protection Act. Early Summary of Ability to Repay and Qualified Mortgage Rules under Dodd-Frank Wall Street Reform and Consumer Protection Act January 11, 2013 OVERVIEW - On January 10, 2013, the Consumer Financial Protection

More information

Dodd Frank Act Consumer Financial Protection Bureau Mortgage Lending

Dodd Frank Act Consumer Financial Protection Bureau Mortgage Lending Dodd Frank Act Consumer Financial Protection Bureau Mortgage Lending A Briefing for the Texas House Investments and Financial Services Committee John C. Fleming Consumer Financial Protection Bureau (CFPB)

More information

CFPB THE NEW DISCLOSURE FORMS AND REQUIREMENTS BE READY!!

CFPB THE NEW DISCLOSURE FORMS AND REQUIREMENTS BE READY!! CFPB THE NEW DISCLOSURE FORMS AND REQUIREMENTS BE READY!! CELIA C. FLOWERS FLOWERS DAVIS, P.L.L.C. and EAST TEXAS TITLE COMPANY Tyler, Texas 75701 TILA and RESPA History 2012 TEXAS LAND TITLE INSTITUTE

More information

The Federal Register published the proposed rule on August 23, 2012.

The Federal Register published the proposed rule on August 23, 2012. CFPB Issues Draft RESPA-TILA Proposed Rules On July 9, the Consumer Financial Protection Bureau ( Bureau or CFPB ) released draft proposed rules and model forms that combine the required disclosures under

More information

AMERICAN BAR ASSOCIATION CONSUMER FINANCIAL SERVICES COMMITTEE SPRING MEETING SAN FRANCISCO, CALIFIORNIA

AMERICAN BAR ASSOCIATION CONSUMER FINANCIAL SERVICES COMMITTEE SPRING MEETING SAN FRANCISCO, CALIFIORNIA AMERICAN BAR ASSOCIATION CONSUMER FINANCIAL SERVICES COMMITTEE SPRING MEETING SAN FRANCISCO, CALIFIORNIA TILA-RESPA INTEGRATED DISCLOSURE RULE BACKGROUND, TILA LIABILITIES & OPERATIONAL CONCERNS I. OVERVIEW

More information

Mortgage Servicing Rules (RESPA) Proprietary (non-hamp) Loss Mitigation

Mortgage Servicing Rules (RESPA) Proprietary (non-hamp) Loss Mitigation Mortgage Servicing Rules (RESPA) Proprietary (non-hamp) Loss Mitigation Generally Regulation X does not require a servicer to provide any specific loss mitigation option, including the opportunity to apply

More information

SEC auditor independence considerations

SEC auditor independence considerations SEC auditor independence considerations When a PEG has a registered investment adviser September 2013 The Dodd-Frank Wall Street Reform and Consumer Protection Act requires most advisers of private funds

More information

Mon. ICBA Summary of the Military Lending Act Updated Regulation. August 2015. Month Year. Contact:

Mon. ICBA Summary of the Military Lending Act Updated Regulation. August 2015. Month Year. Contact: ICBA Summary of the Military Lending Act Updated Regulation August 2015 Month Year Mon Contact: Joe Gormley Assistant Vice President & Regulatory Counsel joseph.gormley@icba.org www.icba.org ICBA Summary

More information

Regulatory Practice Letter June 2012 RPL 12-11

Regulatory Practice Letter June 2012 RPL 12-11 Regulatory Practice Letter June 2012 RPL 12-11 Mortgage Rule Modifications under CFPB Consideration Executive Summary The Bureau of Consumer Financial Protection ( CFPB ) has announced that it intends

More information

Why real estate professionals, mortgage lenders and closing agents have to coordinate tasks during a real estate transaction.

Why real estate professionals, mortgage lenders and closing agents have to coordinate tasks during a real estate transaction. Why real estate professionals, mortgage lenders and closing agents have to coordinate tasks during a real estate transaction. The new Closing Disclosure replaces the current HUD-1 Settlement Statement

More information

Equal Credit Opportunity Act (ECOA) Valuations Rule

Equal Credit Opportunity Act (ECOA) Valuations Rule MAY 2, 2013 Equal Credit Opportunity Act (ECOA) Valuations Rule SMALL ENTITY COMPLIANCE GUIDE 1 Table of Contents 1. Introduction... 5 I. What is the purpose of this guide?... 6 II. Who should read this

More information

All in Good Faith. mortgagedashboard. How Know Before You Owe Changes Everything. Jorge Sauri jorges@mortgagedashboard.com

All in Good Faith. mortgagedashboard. How Know Before You Owe Changes Everything. Jorge Sauri jorges@mortgagedashboard.com All in Good Faith How Know Before You Owe Changes Everything. Jorge Sauri jorges@mortgagedashboard.com mortgagedashboard August 1, 2015, marks the end of a long road for federal regulations that promise

More information

TILA Escrow Requirements for High Priced Mortgage Loans (12 CFR 1026.35)

TILA Escrow Requirements for High Priced Mortgage Loans (12 CFR 1026.35) TILA Escrow Requirements for High Priced Mortgage Loans (12 CFR 1026.35) The Consumer Financial Protection Bureau s (CFPB) mortgage rules include new escrow account requirements for higher-priced mortgage

More information

A Primer on the New CFPB Regulations Governing Residential Closings. Navigating the New Forms (Loan Estimate and Closing Disclosure.

A Primer on the New CFPB Regulations Governing Residential Closings. Navigating the New Forms (Loan Estimate and Closing Disclosure. A Primer on the New CFPB Regulations Governing Residential Closings. Navigating the New Forms (Loan Estimate and Closing Disclosure.) For loan applications received beginning October 3, 2015. Disclaimer:

More information

Title Insurance Tips and Tricks. Presented by: Katie Droscha

Title Insurance Tips and Tricks. Presented by: Katie Droscha Title Insurance Tips and Tricks Presented by: Katie Droscha Tips and Tricks The 2006 ALTA Loan Policy Endorsements Real Life Claims The CFPB 2006 ALTA Loan Policy 14 Covered Risks Validity, priority and

More information

NCUA LETTER TO CREDIT UNIONS

NCUA LETTER TO CREDIT UNIONS NCUA LETTER TO CREDIT UNIONS NATIONAL CREDIT UNION ADMINISTRATION 1775 Duke Street, Alexandria, VA 22314 DATE: August 2008 LETTER NO.: 08-CU-19 TO: SUBJ: Federally Insured Credit Unions Third-Party Relationships:

More information

NEW CFPB RULES FOR HIGH COST MORTGAGES AND HOMEOWNERSHIP COUNSELING February 3, 2013

NEW CFPB RULES FOR HIGH COST MORTGAGES AND HOMEOWNERSHIP COUNSELING February 3, 2013 NEW CFPB RULES FOR HIGH COST MORTGAGES AND HOMEOWNERSHIP COUNSELING February 3, 2013 On January 10, 2013, the Consumer Financial Protection Bureau ( CFPB ) issued a final rule that carries out changes

More information

CFPB s Final Mortgage Regulations:

CFPB s Final Mortgage Regulations: CFPB s Final Mortgage Regulations: Ability-to-Repay and Qualified Mortgage Rules November 4, 2013 E. Andrew Keeney, Esq. Kaufman & Canoles, P.C. Ability-to-Repay and Qualified Mortgage Rules E. Andrew

More information

Summary of the CFPB s Force-Placed Insurance Proposed Rules

Summary of the CFPB s Force-Placed Insurance Proposed Rules TO: FROM : RE: ABIA Government Relations Committee Barnett, Sivon & Natter, P.C. McIntyre & Lemon, PLLC Summary of the CFPB s Force-Placed Insurance Proposed Rules Date: August 16, 2012 Overview The Bureau

More information

Regulation X Real Estate Settlement Procedures Act

Regulation X Real Estate Settlement Procedures Act Regulation X Real Estate Settlement Procedures Act The Real Estate Settlement Procedures Act of 1974 (RESPA) (12 U.S.C. 2601 et seq.) (the act) became effective on June 20, 1975. The act requires lenders,

More information

Loan Estimate (LE) TILA-RESPA Integrated Disclosure (TRID) Rule Requirements

Loan Estimate (LE) TILA-RESPA Integrated Disclosure (TRID) Rule Requirements Loan Estimate (LE) TILA-RESPA Integrated Disclosure (TRID) Rule Requirements New Definitions; New Forms New Work Flow New Rule creates new definition of Covered Loan Loan Application Consummation (Closing)

More information

FAQs About RESPA for Industry

FAQs About RESPA for Industry FAQs About RESPA for Industry 1. What kinds of transactions are covered under RESPA? Transactions involving a federally related mortgage loan, which includes most loans secured by a lien (first or subordinate

More information

Sample. Provide the highest level of risk review and compliance measurement.

Sample. Provide the highest level of risk review and compliance measurement. Introduction Goals Client Chapter 1 Introduction Mortgage quality control programs are critical to the operations of a mortgage company. Quality control programs can maximize the effectiveness of mortgage

More information

MORTGAGE TERMS. Assignment of Mortgage A document used to transfer ownership of a mortgage from one party to another.

MORTGAGE TERMS. Assignment of Mortgage A document used to transfer ownership of a mortgage from one party to another. MORTGAGE TERMS Acceleration Clause This is a clause used in a mortgage that can be enforced to make the entire amount of the loan and any interest due immediately. This is usually stipulated if you default

More information

Module 3. The disclosure requirements are discussed separately below.

Module 3. The disclosure requirements are discussed separately below. Page 1 of 29 Module 3 Adverse Action Disclosures - Section 615(a) and (b); 15 U.S.C. 1681m(a) and (b) Section 615(a)-(b) requires users of consumer reports, such as creditors, to make certain disclosures

More information

State Bank Commissioner Consumer and Mortgage Lending Division

State Bank Commissioner Consumer and Mortgage Lending Division Agency 75 State Bank Commissioner Consumer and Mortgage Lending Division Editor s Note: The office of the consumer credit commissioner was abolished on July 1, 1999. Powers, duties and functions of the

More information

CFPB Loan Disclosure Rules: Know Before You Owe Mortgage Forms The New Requirements and Their Impact on Financial Institutions

CFPB Loan Disclosure Rules: Know Before You Owe Mortgage Forms The New Requirements and Their Impact on Financial Institutions CFPB Loan Disclosure Rules: Know Before You Owe Mortgage Forms The New Requirements and Their Impact on Financial Institutions David A. Elliott Partner Richard C. Keller Partner OUTLINE Section 1032(f)

More information

A New Era in Closings CFPB s Final Rule for Integrated Mortgage Disclosures. Michelle L. Korsmo Chief Executive Officer Steven Gottheim Counsel

A New Era in Closings CFPB s Final Rule for Integrated Mortgage Disclosures. Michelle L. Korsmo Chief Executive Officer Steven Gottheim Counsel A New Era in Closings CFPB s Final Rule for Integrated Mortgage Disclosures Michelle L. Korsmo Chief Executive Officer Steven Gottheim Counsel Agenda Basics: Why We re Here Final Rule The New Forms Evaluating

More information

Case 1:14-cv-01028-RMC Document 65-8 Filed 09/30/14 Page 1 of 10 EXHIBIT G

Case 1:14-cv-01028-RMC Document 65-8 Filed 09/30/14 Page 1 of 10 EXHIBIT G Case 1:14-cv-01028-RMC Document 65-8 Filed 09/30/14 Page 1 of 10 EXHIBIT G Case 1:14-cv-01028-RMC Document 65-8 Filed 09/30/14 Page 2 of 10 STATE RELEASE I. Covered Conduct For purposes of this Release,

More information

CFPB Regulations. Review & Enforcement

CFPB Regulations. Review & Enforcement CFPB Regulations Review & Enforcement Agenda Welcome Overview 2014 Regulations Loan Originator Compensation and Training, Certification, and Identifier Disclosure High-Cost/HOEPA Mortgage Loans & Homeownership

More information

AGREEMENT BY AND BETWEEN The Bank of Maine Portland, Maine and The Comptroller of the Currency

AGREEMENT BY AND BETWEEN The Bank of Maine Portland, Maine and The Comptroller of the Currency AGREEMENT BY AND BETWEEN The Bank of Maine Portland, Maine and The Comptroller of the Currency #2012-167 The Bank of Maine, Portland, Maine ( Bank ) and the Comptroller of the Currency of the United States

More information