As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Act), enacted in 2018, directs the CFPB to prescribe regulations that apply Truth in Lending Act (TILA) ability-to-repay (ATR)...more
The CFPB recently issued a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan (HPML)....more
12/24/2024
/ Asset Management ,
Consumer Financial Protection Bureau (CFPB) ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
Escrow Accounts ,
Exemptions ,
Final Rules ,
High-Priced Mortgage Loans (HPML) ,
Loans ,
Mortgages ,
Regulation Z ,
Threshold Requirements ,
Truth in Lending Act (TILA)
As previously reported, this summer the U.S. Department of Housing and Urban Development (HUD) filed a housing discrimination charge under the Fair Housing Act against an appraisal company, individual appraiser, appraisal...more
12/18/2024
/ Appraisal ,
Appraisers ,
Declaratory Judgments ,
Discriminatory Lending Practices ,
Disparate Impact ,
Enforcement Actions ,
Fair Housing Act (FHA) ,
Housing Market ,
HUD ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Statutory Violations ,
Truth in Lending Act (TILA)
The CFPB has issued a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z under the Truth in Lending Act (TILA) that implement the CARD Act, Home Ownership and Equity...more
The National Consumer Law Center is asking the CFPB, by way of a petition, for rulemaking that is long on policy arguments but woefully short on legal support, as we note below, to define residential leases as “credit” under...more
8/28/2024
/ Administrative Procedure Act ,
Anti-Discrimination Policies ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Credit Reports ,
Creditors ,
Data Collection ,
ECOA ,
Fair Credit Reporting Act (FCRA) ,
Final Rules ,
Financial Services Industry ,
NCLC ,
Proposed Rules ,
Regulation B ,
Regulation Z ,
Residential Leases ,
Small Business ,
Truth in Lending Act (TILA)
The Consumer Financial Protection Bureau (CFPB), recently issued a Request for Information (RFI) related to fees charged by providers of mortgages and related settlement services. In his statement, Director Chopra discussed...more
6/19/2024
/ Administrative Procedure Act ,
Closing Costs ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Reporting Agencies ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Request For Information ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Truth in Lending Act (TILA)
The U.S. Department of Housing and Urban Development (HUD), through the Federal Housing Administration (FHA), recently issued Mortgagee Letter 2024-07 addressing reconsideration of value (ROV) policies in connection with...more
5/10/2024
/ Appraisal ,
Bias ,
Borrowers ,
Fannie Mae ,
Federal Housing Administration (FHA) ,
Financial Services Industry ,
Freddie Mac ,
HUD ,
Mortgagee Letters ,
Mortgages ,
Regulation Z ,
Truth in Lending Act (TILA)
The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA)...more
The CFPB has released its Fall 2023 rulemaking agenda as part of the Fall 2023 Unified Agenda of Federal Regulatory and Deregulatory Actions. The agenda’s preamble indicates that “[t]he Bureau reasonably anticipates having...more
12/8/2023
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Dodd-Frank ,
Fair Credit Reporting Act (FCRA) ,
Financial Regulatory Reform ,
Financial Services Committee ,
Financial Services Industry ,
Late Fees ,
Mortgage Servicing Rules ,
Overdraft Fees ,
Popular ,
Regulation DD ,
Regulation Z ,
Regulatory Agenda ,
Truth in Lending Act (TILA)
The CFPB recently approved an application (Application) from the Independent Community Bankers Association (ICBA) for alternative disclosures under the Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA)...more
11/29/2023
/ Construction Industry ,
Construction Loans ,
Construction Project ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Financial Institutions ,
Financial Services Industry ,
Independent Community Bankers of America (ICBA) ,
Mortgages ,
Real Estate Development ,
RESPA ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Truth in Lending Act (TILA)
The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more
11/15/2023
/ Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Exemptions ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financial Transactions ,
Inflation Adjustments ,
Loans ,
Mortgages ,
OCC ,
Proposed Rules ,
Regulation M ,
Regulation Z ,
Threshold Requirements ,
Truth in Lending Act (TILA)
Pursuant to section 1473(q) of the Dodd-Frank Act, a group of federal agencies have proposed a quality control rule for automated valuation models (AVMs). The agencies are the Comptroller of the Currency, Consumer Financial...more
The Economic Growth, Regulatory Relief, and Consumer Protection Act (Act) directs the CFPB to prescribe Truth in Lending Act (TILA) ability-to-repay (ATR) rules for Property Assessed Clean Energy (PACE) financing. The CFPB...more
The CFPB recently announced that it is seeking input on a trial disclosure sandbox application from the Independent Community Bankers Association (ICBA) for alternative disclosures under the Truth in Lending Act (TILA)/Real...more
The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA)...more
On December 23, the CFPB published a final rule in the Federal Register regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability...more
A Connecticut federal district court has refused to dismiss claims filed by the CFPB against a mortgage company and three of its principals for alleged Truth in Lending Act (TILA), Mortgage Act and Practice (MAP) Rule, and...more
The CFPB recently published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more
As previously reported, the creation on June 17, 2021 of the Juneteenth National Independence Day resulted in an important change under the Truth in Lending Act (TILA) and Regulation Z. The CFPB recently issued an...more
As previously reported, the bill signed into law by President Biden on June 17, 2021 to create the Juneteenth National Independence Day actually results in an important change under the Truth in Lending Act (TILA) and...more
The bill signed into law by President Biden on June 17, 2021 to create the Juneteenth National Independence Day results in an important change under the Truth in Lending Act (TILA) and Regulation Z....more
The CFPB recently entered into a consent order with Nationwide Equities Corporation (Nationwide), which the CFPB refers to as a mortgage broker and mortgage lender that primarily provides jumbo reverse mortgage loans and Home...more
The CFPB recently filed a complaint in the United States District Court for the District of Connecticut alleging violations of various federal consumer protection laws by 1st Alliance Lending, LLC (1st Alliance), a former...more
The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA)...more
As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Growth Act), also known as S.2155, directs the CFPB to implement an exemption from the mandatory escrow account requirement for...more
7/7/2020
/ Consumer Financial Protection Bureau (CFPB) ,
Credit Unions ,
Creditors ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
Escrow Accounts ,
Exemptions ,
High-Priced Mortgage Loans (HPML) ,
Mortgage Lenders ,
Proposed Regulation ,
Regulation Z ,
Truth in Lending Act (TILA)