On August 16, 2010, the Federal Reserve Board (“Board”) issued two proposed rules and three final rules governing federal Truth-in-Lending requirements for residential mortgage loans. This Client Alert summarizes the Board’s proposal relating to mandatory escrow account requirements for first lien higher-priced mortgage loans (“HPMLs”). If it is issued in final form, this proposal will conform the mandatory escrow account requirements for first lien HPMLs to those imposed by the Wall Street Reform and Consumer Financial Protection Act of 2010 (“Dodd-Frank Act”).

Later Client Alerts will address the Board’s remaining proposals and final rules.