60-Second Compliance Summary. REGULATION Z Truth in Lending Closed-End Credit. Unit
|
|
- Blake May
- 8 years ago
- Views:
Transcription
1 Unit 1 REGULATION Z Truth in Lending Closed-End Credit 60-Second Compliance Summary Establishes comprehensive disclosure requirements for consumer credit products Protects consumers against unfair credit billing practices Provides consumers with rescission rights Imposes limitations on certain closed-end home mortgage loans Delineates and prohibits unfair and deceptive mortgage lending practices Does not mandate how much interest banks may charge Most recent rulemaking addressed comprehensive mortgage reform mandated by the Dodd-Frank Act
2 Chapter 1 Overview Truth in Lending legislation was enacted on May 29, 1968, (15 U.S.C 1601 et seq.) and was intended by Congress to promote consistent and informed use of Consumer Credit. T he Truth in Lending Act is implemented by Regulation Z and became effective July 1, The regulation requires creditors to disclose the terms and cost of consumer credit transactions. The Regulation promotes disclosing consistent credit information to consumers: it does not regulate the cost or charge of the credit itself. State usury laws typically regulate the cost of credit. The Regulation also provides consumers the right to cancel certain transaction secured by their principal dwelling, as well as private education loans. Regulation Z implements several laws or acts. It incorporates rules governing credit card practices (Fair Credit Billing Act & Fair Credit and Charge Card Disclosure Act), interest rate ceilings for adjustable rate mortgages (Competitive Equality Banking Act) adverse actions regarding home equity lines of credit (Home Equity Loan Consumer Protection Act), disclosure requirements for dwelling secured loans (Mortgage Disclosure Improvement Act of 2008), open-end consumer credit (Credit Card Accountability and Disclosure Act of 2009), notices when a mortgage loan is sold or transferred (Helping Families Save Their Homes Act of 2009), and consumer protection reforms (Dodd-Frank Act). The Regulation also provides a means for resolving credit card billing disputes. Regulation Z has experienced significant amendments since 2008, beginning with changes to implement the Mortgage Disclosure Improvement Act and most recently, amendments related to the Dodd-Frank Act. The flurry of changes have also included several proposals that were issued and subsequently withdrawn (for example, open-end credit proposal in 2008) compounding the challenge to keep up with the status of the evolving regulation. With the establishment of the Consumer Financial Protection Bureau and the requirement for certain RESPA and Regulation Z disclosures to be integrated, the changes will likely continue for the next several years. Independent Community Bankers of America 1 Bequeaith Banking Solutions, LLC
3 ICON KEY Valuable information Test your knowledge Auditor review Take a closer look A new concept Regulatory Citation Pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2012 (Dodd-Frank Act), the Bureau has been transferred authority of this particular regulation. Formerly, the Federal Reserve Board carried the responsibility of writing and amending this regulation. The regulation is now codified at 12 CFR Current events Format of Regulation Z The disclosure requirements of Regulation Z are set forth in several distinct subparts within the regulation. The type of consumer credit product generally determines the subparts creditors must follow to achieve compliance. Subpart A General Provisions ( ) This subpart provides general information that applies to both open-end and closed-end credit transactions. An important section to consult is the section containing rules for determining which fees are finance charges. Subpart B Open-End Credit ( ) This subpart relates to open-end credit and contains rules on account-opening disclosures and periodic statement delivery. Subpart C Closed-End Credit ( ) This subpart contains provisions applicable to closed-end credit. It addresses disclosure requirements for account opening, APR calculations, and rescission requirements. Subpart D Miscellaneous Provisions ( ) This subpart contains requirements regarding oral disclosures, disclosures in other languages, record retention, state law impacts, and rate limitations. Subpart E Certain Mortgage Transactions ( ) This subpart contains rules addressing certain mortgage transactions, including loans subject to HOEPA and HPML requirements. Additionally, it contains requirements for reverse mortgage transactions and rules on valuation independence requirements. Requirements applicable to home equity plans have also been included in this subpart. Subpart F Private Education Loans ( ) This subpart contains requirements for private education loans including disclosure rules, limitations on changing terms of such loans, the right to cancel this type of loan, and cobranding restrictions. Independent Community Bankers of America 2 Bequeaith Banking Solutions, LLC
4 Subpart G Credit Cards & Other Specific Open-End Credit ( ) This subpart outlines the compliance requirements applicable to credit card and charge card accounts. This subpart was established by directive within the Credit Card Act. Appendices & Official Staff Interpretations (Appendix A-N, Supplement) A critical element to the overall implementing regulation and practical application of the rules is the establishment of the appendices and official staff interpretations. These sections provide for comprehensive model forms, calculation methods, and official staff interpretations. General Provisions A Creditor is: [1026.2(a)(17)] 1. A person (natural person, organization, corporation, partnership, etc.) who regularly extends consumer credit that is subject to a finance charge. OR 2. A person that extends consumer credit evidenced by a written agreement which is payable in four or more installments. ("regularly" = more than 25 times in a calendar year or more than 5 times if secured by a dwelling.) AND (#1 or #2, plus #3) 3. The person is the initial person extending consumer credit. Why do we check disclosures on indirect paper? While we're not the initial creditor and not subject to criminal violations, we can still "buy" civil liability. Effective January 5, 1996: Assignees of transactions secured by real property may be liable for violations if the violation is apparent on the face of the disclosure statement and assignment was voluntary. What Obligations Must be Disclosed? Coverage [1026.1(c) Credit is extended to consumers Credit is primarily for personal or household purposes Credit is subject to finance charge or payable in more than four installments Offering or extension of credit is done regularly What Obligations are Not Disclosed? [1026.3] Business, Agricultural, & Organizational Credit Reg Z does not apply to business, agricultural or organizational credit [1026.3(a)]. Furthermore, business-purpose credit cards issued to employees are not subject to the Independent Community Bankers of America 3 Bequeaith Banking Solutions, LLC
5 provisions of Reg Z. Liability falls on the card holder even if unauthorized use of a business credit card is for consumer-purpose transactions. There are five determining factors to distinguish between personal and business purpose if unsure. [Commentary (a)(2)] 1. The relationship of the borrower's primary occupation to the acquisition. The more closely related, the more likely it is to be business purpose. 2. The degree to which the borrower will personally manage the acquisition. The more personal involvement there is, the more likely it is to be business purpose. 3. The ratio of income from the acquisition to the total income of the borrower. The higher the ratio, the more likely it is to be business purpose. 4. The size of the transaction. The larger the transaction, the more likely it is to be business purpose. 5. The borrower's statement of purpose for the loan. Note: See page #1 of the Regulation Z Appendix for the Coverage Considerations diagram. Rental Property Special exemption rules apply to Rental Property. Non-owner occupied rental property is exempt unless the property is occupied by the owner for more than 14 days. For owner occupied rental property to be exempt the property must have more than two units. Or the owner occupied property must Independent Community Bankers of America 4 Bequeaith Banking Solutions, LLC
6 Consumer Credit > $53,000 Consumer credit over $53,000 not secured by real property or personal property used as the consumer s principal dwelling. *Effective 7/21/2011, the dollar threshold will be adjusted annually to reflect any increase in the consumer price index. [1026.3(b)] The annual adjustments may be found in the Reg Z Commentary. Personal property includes mobile homes. If a loan is to a consumer > $53,000, made for a consumer purpose and secured by any real property, THE TRANSACTION MUST BE DISCLOSED. Private education loans as defined in (b)(5) are subject to Reg Z requirements and THE TRANSACTION MUST BE DISCLOSED. Student Loan Programs Some student loan programs are exempt. These are loans guaranteed by Title IV of the Higher Education Act of 1965 GSL s, PLUS s & National Direct Student Loans. Public Utility Credit & Securities Public utility credit, securities or commodities accounts and home fuel budget plans are also exempt from Reg Z requirements. Mixed Purpose Loans Mixed purpose loans require a greater understanding of the transaction. The regulation states: Figure out the primary purpose of the loan. (i.e. for what purpose does the majority of loan proceeds go toward?). Best practice is when in doubt, disclose. Finance Charge [1026.4] VIP to understanding and treating new charges properly; but recognize that this will likely be one of the fundamental changes going forward. This is the cost, stated as a dollar amount, which the consumer incurs as the result of the credit. This includes charges imposed by the creditor and payable by the consumer. Finance charges do not include items incurred by consumers in comparable cash transactions. This means that taxes, license fees and registration fees incurred by consumers for both cash and credit transactions are not considered finance charges. Generally, treatment of various costs can be divided into the following three groups, and the outline is organized in that manner: Always considered a finance charge Never considered a finance charge Treated as a finance charge unless certain conditions met to allow exclusions Prepaid Finance Charge More of a function of when the fee is incurred. The importance of prepaid finance charges is that those fees are deducted from the loan contract amount to determine the amount financed, an important number in the determination of the annual percentage rate (APR). Any finance charge paid separately in cash or by check before or at consummation of a transaction, or withheld from the proceeds of the credit at any time. Examples: origination fee, odd-days interest, first year mortgage guaranty insurance premium, mortgage Independent Community Bankers of America 5 Bequeaith Banking Solutions, LLC
CFPB Laws and Regulations
Laws and Regulations Truth in Lending Act 1 The Truth in Lending Act (), 15 U.S.C. 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub. L. 90-321). The, implemented
More informationTruth in Lending Act
Comptroller s Handbook CC-TILA Consumer Compliance (CC) Truth in Lending Act December 2014 Office of the Comptroller of the Currency Washington, DC 20219 Contents Introduction...1 Background and Summary...
More information209 CMR: DIVISION OF BANKS AND LOAN AGENCIES
209 CMR 32.00: TRUTH IN LENDING Section GENERAL 32.01: Purpose and Scope 32.02: Definitions and Rules of Construction 32.03: Exempt Transactions 32.04: Finance Charges OPEN END CREDIT 32.05: General Disclosure
More informationTruth in Lending Act 1
Truth in Lending Act 1 The Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub. L. 90-321). The TILA, implemented by
More informationV 1.1. V. Lending TILA. Truth in Lending Act. Introduction
Truth in Lending Act Introduction The Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub. L. 90-321). The TILA, implemented
More informationCFPB Consumer Laws and Regulations
Consumer Laws and Regulations Truth in Lending Act 1 The Truth in Lending Act (), 15 U.S.C. 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub. L. 90-321).
More informationCFPB Consumer Laws and Regulations
Consumer Laws and Regulations Truth in Lending 1 The Truth in Lending Act (), 15 U.S.C. 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub. L. 90-321). The,
More informationV 1.1. V. Lending TILA. Truth in Lending Act 1. Introduction
Truth in Lending Act 1 Introduction The Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub. L. 90-321). The TILA, implemented
More informationCFPB releases exam procedures for new mortgage rules
releases exam procedures for new mortgage rules > Consumer Financial Protection Bureau http://www.consumerfinance.gov/pressreleases/the-cfpb-releases-exam-procedures-for-new-mortg... Page 1 of 2 7/17/2013
More informationThe 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 informationMon. 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 informationQUICK REFERENCE GUIDE TO DISCLOSURES TRUTH IN LENDING ACT AND REGULATION Z (1) (CLOSED-END HOME MORTGAGE TRANSACTIONS)
QUICK REFERENCE GUIDE TO DISCLOSURES TRUTH IN LENDING ACT AND REGULATION Z (1) (CLOSED-END HOME MORTGAGE TRANSACTIONS) Type of (2) Contents of Truth in Lending Statements 226.17 226.36 Early s 226.19(a)(1)
More informationRegulation Z Truth in Lending Act 1
Regulation Z Truth in Lending Act 1 Background The Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub. L. 90-321). The
More informationComparison of Section 35(HPML) & Section 32(HOEPA) Regulations Including CFPB 2013 & 2014 Updates As of 01/07/2014
Comparison of Section 35(HPML) & Section 32(HOEPA) Regulations Including CFPB 2013 & 2014 Updates As of 01/07/2014 General Consumer Loan Type Not Applicable HPML (12 CFR 1026.35) A closed-end consumer
More informationTruth in Lending. Regulation Z. Background. Organization of Regulation Z. Applicability
Regulation Z Truth in Lending Background Regulation Z (12 CFR 226) implements the Truth in Lending Act (TILA) (15 USC 1601 et seq.), which was enacted in 1968 as title I of the Consumer Credit Protection
More informationCCE Consumer Compliance Examination. Truth in Lending. Comptroller s Handbook. October 2008 CCE-TIL
CCE-TIL Comptroller of the Currency Administrator of National Banks Truth in Lending Comptroller s Handbook October 2008 CCE Consumer Compliance Examination Truth in Lending Table of Contents Introduction
More informationTILA Higher-Priced Mortgage Loans (HPML) Escrow Rule
JANUARY 6, 2014 TILA Higher-Priced Mortgage Loans (HPML) Escrow Rule SMALL ENTITY COMPLIANCE GUIDE This guide has been updated for the following changes - the May 2013 Final Rule and October 2013 Final
More informationTruth in Lending (Regulation Z) Annual Threshold Adjustments (CARD ACT, AGENCY: Bureau of Consumer Financial Protection.
This document is scheduled to be published in the Federal Register on 09/21/2015 and available online at http://federalregister.gov/a/2015-22987, and on FDsys.gov Billing Code: 4810-AM-P BUREAU OF CONSUMER
More informationRegulation Z. Background and Summary
Regulation Z Truth in Lending Introduction Background and Summary The Truth in Lending Act (TILA), 15 USC 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub.
More informationHOME OWNERSHIP EQUITY PROTECTION ACT OF 1994. Raymond Natter 1
HOME OWNERSHIP EQUITY PROTECTION ACT OF 1994 Raymond Natter 1 Recent Congressional attention to the problems of predatory mortgage lending has led for calls for the Federal Reserve Board to use its authority
More informationImplications of the Federal Right of Rescission for Lenders and Borrowers
Implications of the Federal Right of Rescission for Lenders and Borrowers An Interactive Day of Building an Effective Community Response to Foreclosures in Wisconsin December 12, 2007 Disclaimer The views
More informationPolicy 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 informationCFPB 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 informationRegulatory 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 informationNEW 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 informationRegulation Z. Background and Summary
Regulation Z Truth in Lending Introduction Background and Summary The Truth in Lending Act (TILA), 15 USC 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub.
More information12 CFR Ch. II (1 1 12 Edition)
226.1 226.32 Requirements for certain closed-end home mortgages. 226.33 Requirements for reverse mortgages. 226.34 Prohibited acts or practices in connection with credit subject to 226.32. 226.35 Prohibited
More informationRegulatory Practice Letter
RPL Number 10-17 Financial Services Regulatory Practice Regulatory Practice Letter ADVISORY Amendments to Mortgage Loan Provisions under Regulation Z Executive Summary The Federal Reserve Board ( Fed )
More informationThe 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 informationThe 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 informationCUNA 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 informationRegulation Z Truth in Lending Act 1
Regulation Z Truth in Lending Act 1 The Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub. L. 90-321). The TILA, implemented
More informationComparison of Section 32(HOEPA) Regulation; Current Rules vs. January 10, 2014 CFPB Changes As of 10/16/14
Comparison of Section 32(HOEPA) Regulation; Current Rules vs. January 10, 2014 CFPB Changes As of 10/16/14 General Loan Type 1994 TILA amendments apply to homeowners that already owned their homes and
More informationCUNA s HOEPA (Home Ownership and Equity Protection Act) CHART (revised 10/22/2013)
What: CFPB s new HOEPA requirements, 12 CFR 1026 Subpart E. HOEPA was initially enacted in 1994 as an amendment to Truth in Lending to address abusive practices in refinancing and home equity mortgage
More informationii. 25(c)(2) Records related to requirements for loan originator compensation and
4. In Supplement I to Part 1026 Official Interpretations: A. Under Section 1026.25 Record Retention: i. Under 25(a) General rule, paragraph 5 is removed. ii. 25(c)(2) Records related to requirements for
More informationOverview. General Requirements
Truth in Lending Act Overview Congress passed legislation increasing the amount and type of credit information disclosed to the consumer through Title I of the Consumer Credit Protection Act of 1968, known
More informationTITLE I-RESIDENTIAL MORTGAGE LOAN ORIGINATION STANDARDS
TITLE I-RESIDENTIAL MORTGAGE LOAN ORIGINATION STANDARDS Residential Mortgage Origination: Adds a number of new regulations and requirements to mortgage loan originators. The bill requires originators to
More informationJanuary 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 information1. Only 20 days to file answer or other responsive pleading to summons and complaint in foreclosure action.
PREDATORY MORTGAGE LENDING FORECLOSURE DEFENSE Attorney Catherine M. Doyle Legal Aid Society of Milwaukee 521 N. 8 th Street Milwaukee, WI 53233 (414) 727-5331 cdoyle@lasmilwaukee.com I. MORTGAGE FORECLOSURE
More informationTILA Higher Priced Mortgage Loans Appraisal Rule
TILA Higher Priced Mortgage Loans Appraisal Rule Promote the informed use of consumer credit by requiring disclosures about its costs and terms Purpose of the TILA HPML Appraisal Rule: Congress enacted
More informationAdvertising Credit And Lease Arrangements: How To Comply With The Truth In Lending Act
Advertising Credit And Lease Arrangements: How To Comply With The Truth In Lending Act The federal Truth in Lending Act ("TILA") governs most consumer credit transactions. Its companion law the Consumer
More informationREGULATORY 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 informationCUNA 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 informationKnow The Rules Truth in Lending and Florida Compliance
Know The Rules Truth in Lending and Florida Compliance Continuing Education for Florida Mortgage Professionals www.bookmarkeducation.com Know The Rules Truth in Lending and Florida Compliance A considerable
More informationRules and Regulations
23289 Rules and Regulations Federal Register Vol. 74, No. 95 Tuesday, May 19, 2009 This section of the FEDERAL REGISTER contains regulatory documents having general applicability and legal effect, most
More informationCFPB 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 informationBUREAU OF CONSUMER FINANCIAL PROTECTION. Truth in Lending Act (Regulation Z) Adjustment to Asset-Size Exemption
BILLING CODE: 4810-AM-P BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1026 Truth in Lending Act (Regulation Z) Adjustment to Asset-Size Exemption Threshold AGENCY: Bureau of Consumer Financial Protection.
More information24-1.1E. Restrictions and limitations on high-cost home loans.
24-1.1E. Restrictions and limitations on high-cost home loans. (a) Definitions. The following definitions apply for the purposes of this section: (1) "Affiliate" means any company that controls, is controlled
More informationAMERICAN 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 informationFRESH. 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 informationSPECIAL ALERT: CFPB PROPOSES SIGNIFICANT EXPANSION OF HMDA REPORTING REQUIREMENTS
SPECIAL ALERT: CFPB PROPOSES SIGNIFICANT EXPANSION OF HMDA REPORTING REQUIREMENTS JULY 30, 2014 On July 24, the Consumer Financial Protection Bureau (the CFPB or Bureau) issued a proposed rule that would
More informationCFPB 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 informationRules and Regulations
11319 Rules and Regulations Federal Register Vol. 76, No. 41 Wednesday, March 2, 2011 This section of the FEDERAL REGISTER contains regulatory documents having general applicability and legal effect, most
More informationICBA Summary of the Home Mortgage Disclosure Act (HMDA) Revisions to Regulation C
ICBA Summary of the Home Mortgage Disclosure Act (HMDA) Revisions to Regulation C November 2015 Month Year Mon Contact: Joe Gormley Assistant Vice President & Regulatory Counsel joseph.gormley@icba.org
More informationTILA 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 informationNational Banker Call
National Banker Call Loan Originator Compensation and HOEPA Final Rules Thursday, June 6, 2013 The information contained in this presentation is for informational purposes only and is provided as a public
More informationDEPARTMENT OF REGULATORY AGENCIES DIVISION OF REAL ESTATE MORTGAGE LOAN ORIGINATORS AND MORTGAGE COMPANIES 4CCR 725-3
DEPARTMENT OF REGULATORY AGENCIES DIVISION OF REAL ESTATE MORTGAGE LOAN ORIGINATORS AND MORTGAGE COMPANIES 4CCR 725-3 8-1-1 MORTGAGE LOAN ORIGINATOR ADVERTISING Pursuant to and in compliance with Title
More information19. In Supplement I to part 1026, under Section 1026.35 Prohibited Acts or Practices
19. In Supplement I to part 1026, under Section 1026.35 Prohibited Acts or Practices in Connection with Higher-Priced Mortgage Loans: A. Under 35(a) Definitions, the heading and paragraphs 1, 2, and 3
More informationEqual 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 informationWall 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 informationRegulation Z Appraisals for Higher Priced Mortgage Loans
Regulation Z Appraisals for Higher Priced Mortgage Loans (12 CFR 1026.35 (c)) October 31, 201 3 In January 2013, the Consumer Financial Protection Bureau and the federal financial institution regulators
More informationThe New Mortgage Lending Process: A 2014 Check-Up and 2015 Planning
The New Mortgage Lending Process: A 2014 Check-Up and 2015 Planning Copyright 2012 Tata Consultancy Services Limited No Legal Advice, Opinions, or Services Provided This presentation does not constitute
More informationBureau of Consumer Financial Protection. No. 158 August 15, 2012. Part III
Vol. 77 Wednesday, No. 158 August 15, 2012 Part III Bureau of Consumer Financial Protection 12 CFR Parts 1024 and 1026 High-Cost Mortgage and Homeownership Counseling Amendments to the Truth in Lending
More informationJune 10, 2010. 2010 Legislative Amendments to the Indiana Code Relating to First Lien Mortgage Act (the Act )
June 10, 2010 2010 Legislative Amendments to the Indiana Code Relating to First Lien Mortgage Act (the Act ) Effective July 1, 2010 (except as otherwise indicated) Questions, Answers, and Administrative
More informationRegulatory 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 informationThe final rule has expanded the scope of covered products how does this impact your business?
January 2016 Military Lending Act It s time to get prepared The final rule has expanded the scope of covered products how does this impact your business? Overview A joint point of view by PwC s Consumer
More informationCFPB 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 informationFinancial Regulatory Reform: The New Rules on Loan Originator Compensation
Financial Regulatory Reform: The New Rules on Loan Originator Compensation 1 Introduction NOTICE: This information is not intended to be used as legal advice to any person or entity. The information contained
More informationMLO COMPENSATION, REGULATION Z, AND DODD-FRANK ACT
MLO COMPENSATION, REGULATION Z, AND DODD-FRANK ACT Vermont Mortgage Bankers Association & Mortgage Bankers/Brokers Association of NH Mortgage Compliance Conference Thursday, March 3, 2011 Sean P. Mahoney
More informationTalent Amendment Limitations on Terms of Consumer Credit Extended to Service Members and Dependents
Talent Amendment Limitations on Terms of Consumer Credit Extended to Service Members Dependents Background Department of Defense (DoD) regulations implementing the consumer protection provisions of the
More informationHouse of Representatives
House of Representatives General Assembly File No. 44 February Session, 2002 Substitute House Bill No. 5073 House of Representatives, March 18, 2002 The Committee on Banks reported through REP. DOYLE of
More informationHigh-Cost Mortgage and Homeownership Counseling Amendments to the Truth in
BUREAU OF CONSUMER FINANCIAL PROTECTION BILLING CODE: 4810-AM-P 12 CFR Parts 1024 and 1026 [Docket No. CFPB-2012-0029] RIN 3170-AA12 High-Cost Mortgage and Homeownership Counseling Amendments to the Truth
More informationPlaintiffs, V. AP #01-2104. Defendants. BACKGROUND. On May 17, 2001, Penny R. Nunn (the Debtor ) filed a
UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF NEW YORK In re: PENNY R. NUNN, CASE NO. 01-21920 Debtors. DECISION & ORDER PENNY R. NUNN, IMC MORTGAGE COMPANY, Plaintiffs, V. AP #01-2104 Defendants.
More informationSubject: Compliance Bulletin: Private Mortgage Insurance Cancellation and Termination
CFPB Bulletin 2015-03 Date: August 4, 2015 Subject: Compliance Bulletin: Private Mortgage Insurance Cancellation and Termination The Bureau of Consumer Financial Protection (CFPB) is issuing this compliance
More informationINFOBYTES SPECIAL ALERT: DETAILED ANALYSIS OF CFPB S FINAL ESCROW RULE
INFOBYTES SPECIAL ALERT: DETAILED ANALYSIS OF CFPB S FINAL ESCROW RULE FEBRUARY 15, 2013 On January 10, 2013, the Consumer Financial Protection Bureau (the Bureau ) issued its final rule (the Rule or Escrow
More informationSTATE HIGH COST/PREDATORY LENDING REGULATIONS Updated 1/10/2014
STATE HIGH COST/PREDATORY LENDING REGULATIONS Updated 1/10/2014 State: Law: Cite: North Carolina NC High Cost Home Loan Law NC Rate Spread Home Loans Check both rules HB 2188 effective 10/01/2008 changes
More informationPlease see Section IX. for Additional Information:
The Florida Senate BILL ANALYSIS AND FISCAL IMPACT STATEMENT (This document is based on the provisions contained in the legislation as of the latest date listed below.) Prepared By: The Professional Staff
More informationP. O. BOX 19999, RALEIGH, NC 27619-9916 / 800/662-7044 / FAX: 919/881-9909. Regulatory Review
FINAL RULE P. O. BOX 19999, RALEIGH, NC 27619-9916 / 800/662-7044 / FAX: 919/881-9909 Regulatory Review RR 2010-11 OCTOBER 14, 2010 ***************IN THIS ISSUE*************** Revisions to Rules Implementing
More informationCFPB and Lenders. A presentation on the Consumer Financial Protection Bureau and its impact on the lending industry
CFPB and Lenders A presentation on the Consumer Financial Protection Bureau and its impact on the lending industry What is the Consumer Financial Protection Bureau (CFPB)? Independent agency of the United
More informationCOLORADO CONSUMER EQUITY PROTECTION ACT July 1, 2011
COLORADO CONSUMER EQUITY PROTECTION ACT July 1, 2011 Table of Contents COLORADO CONSUMER EQUITY PROTECTION ACT... 1 PART 1 OBLIGOR PROTECTION... 1 5-3.5-101. Definitions.... 1 5-3.5-102. Protection of
More informationSTATE OF RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION DIVISION OF BANKING 233 RICHMOND STREET, SUITE 231 PROVIDENCE, RHODE ISLAND 02903
TABLE OF CONTENTS STATE OF RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION DIVISION OF BANKING 233 RICHMOND STREET, SUITE 231 PROVIDENCE, RHODE ISLAND 02903 BANKING REGULATION 3 HOME LOAN PROTECTION ACT
More information2013 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 informationHow 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 informationCourse Description for RELET
Federal Reserve Board Course Description for RELET Course Catalog Detail Type of Participant Targeted Real Estate Lending Examination Techniques (RELET) course is designed for Federal Reserve System consumer
More informationBreak Out Session: Mortgage Loan Underwriting and Pricing
Break Out Session: Mortgage Loan Underwriting and Pricing Agenda Ability to Repay (ATR)/Qualified Mortgages (QMs) Effective Date: Applications received on or after January 10, 2014 2013 Home Ownership
More informationCLARIFICATION 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 informationP. O. BOX 19999, RALEIGH, NC 27619-9916 / 800/662-7044 / FAX: 919/881-9909. Regulatory Review RR 2011-03 MARCH 25, 2011
FINAL RULE P. O. BOX 19999, RALEIGH, NC 27619-9916 / 800/662-7044 / FAX: 919/881-9909 Regulatory Review RR 2011-03 MARCH 25, 2011 ***************IN THIS ISSUE*************** Truth-in-Lending Rate Threshold
More informationChanges 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 informationLoan Originator Compensation: The New Paradigm
Loan Originator Compensation: The New Paradigm Presented for Maryland Association of Mortgage Professionals on March 3, 2011 by Marjorie A. Corwin Gordon, Feinblatt, Rothman, Hoffberger & Hollander, LLC
More informationMRS Title 9-A 8-103. Definitions and rules of construction
9-A 8-103. Definitions and rules of construction The text included in this publication was prepared by the Maine Bureau of Financial Institutions and is current through July 15, 2008. It is a version that
More informationSmall Business Review Panel for HMDA Rulemaking
Submitted electronically June 11, 2014 The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Small Business Review Panel for HMDA Rulemaking
More informationTILA Higher-Priced Mortgage Loans (HPML) Appraisal Rule
JANUARY 13, 2014 TILA Higher-Priced Mortgage Loans (HPML) Appraisal Rule SMALL ENTITY COMPLIANCE GUIDE Version Log The Bureau updates this guide on a periodic basis to reflect finalized clarifications
More information2013 Home Ownership and Equity Protection Act (HOEPA) Rule
MAY 2, 2013 2013 Home Ownership and Equity Protection Act (HOEPA) Rule SMALL ENTITY COMPLIANCE GUIDE The Bureau recently finalized changes to this rule. The revisions amend the final rule issued January
More informationTitle 9-A: MAINE CONSUMER CREDIT CODE
Maine Revised Statutes Title 9-A: MAINE CONSUMER CREDIT CODE Article : 8-506. ENHANCED RESTRICTIONS ON CERTAIN CREDITORS In addition to the compliance requirements of section 8-504, subsection 1, unless
More informationEscrow Requirements under the Truth in Lending Act (Regulation Z)
BILLING CODE: 4810-AM-P BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1026 [Docket No. CFPB-2013-0001] RIN No. 3170-AA16 Escrow Requirements under the Truth in Lending Act (Regulation Z) AGENCY:
More informationSenate Bill 1149 Summary -- Prohibit Predatory Lending
MEMORANDUM TO: FROM: Hal D. Lingerfelt Commissioner of Banks L. McNeil Chestnut Assistant Attorney General DATE: August 25, 1999 RE: Senate Bill 1149 Summary -- Prohibit Predatory Lending I. Background
More informationARCHIVE. Table of Contents. 12.01.10 - Rules Pursuant to the Idaho Residential Mortgage Practices Act
Table of Contents 12.01.10 - Rules Pursuant to the Idaho 000. Legal Authority (Rule 0).... 2 001. Title And Scope (Rule 1).... 2 002. Written Interpretations -- Agency Access -- Filings (Rule 2).... 2
More informationMortgage Loan Originator Compensation (12 CFR 1026)
Mortgage Loan Originator Compensation (12 CFR 1026) In January 2013, the Consumer Financial Protection Bureau (CFPB) amended Regulation Z to implement requirements imposed by the Dodd-Frank Act concerning
More information