The U.S. Department of Veterans Affairs (VA) recently proposed rules under its home loan guaranty program regarding adjustable rate mortgage (ARM) loans, hybrid ARM (h-ARM) loans and temporary buydown agreements. Comments are...more
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
On March 8, 2024, the Consumer Financial Protection Bureau (CFPB) announced it was seeking public input on so-called “junk fees” incurred as part of the closing process for residential mortgage loans. The residential...more
The Consumer Financial Protection Bureau (CFPB) has approved an application from the Independent Community Bankers of America (ICBA) to pilot disclosures for construction loans, paving the way for lenders to use and test the...more
Late last week, the Consumer Financial Protection Bureau (CFPB) released an interpretive rule that provided much-welcome guidance related to the effect of the new Juneteenth National Independence Day on disclosure waiting...more
So what happened at the CFPB in the past month? Bite #10 - The CFPB released its Spring 2021 rulemaking Agenda. The CFPB published its Spring 2021 rulemaking Agenda, which outlines the current plans for the CFPB...more
On June 17, 2021, President Joe Biden signed into law Juneteenth National Independence Day Act. The enactment of the new Federal holiday was an historic and welcome national event. ...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
On October 1, 2020, the Consumer Financial Protection Bureau (CFPB) released its rule assessment for a final Rule relating to mortgage disclosures. Known as the TRID Rule, the Bureau’s final Rule implemented requirements...more
On June 9 the Consumer Financial Protection Bureau (CFPB) published a Factsheet on how to disclose title insurance on the Loan Estimate and Closing Disclosure, including when a negative owner’s title insurance cost disclosure...more
On June 9, 2020, the CFPB published four new TRID FAQ’s and a TRID Factsheet (“Factsheet”). While the Factsheet is focused solely on the handling of title insurance disclosures under the rule, the FAQ’s cover various topics,...more
TRID Rescission Waiver Rule & ECOA Valuations FAQ - On April 29, 2020, the Consumer Financial Protection Bureau (CFPB) released additional information which Director Kathleen Kraninger said she hopes “will help consumers...more
The CFPB recently published 10 new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more
The CFPB recently published ten new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more
Federal Reserve Announces Plan for Real-Time Payment and Settlement Service - The Federal Reserve has announced that the Federal Reserve Banks will develop a new real-time gross settlement service with integrated clearing...more
The CFPB recently updated the TRID rule FAQs to address questions about providing a Loan Estimate to consumers. The FAQs mostly confirm guidance previously provided by the CFPB in various forms. ...more
On July 11, 2019, I presented at the American Bankers Association webinar, entitled, “Mortgage Disclosure Cures and Corrections — Mitigating Liability.” Below is a summary of the points presented in the webinar and additional...more
On May 1, 2019, the Consumer Financial Protection Bureau (CFPB) released a Fact Sheet on the application of the TILA-RESPA Integrated Disclosure Rule (TRID) to assumptions of residential mortgage loans. The Fact Sheet appears...more
For years, the mortgage industry has urged the CFPB to issue informal written guidance on the TILA/RESPA Integrated Disclosure (TRID) Rule, as well as other rules. ...more
The CFPB recently issued revised TILA/RESPA Integrated Disclosure (TRID) rule guides to reflect the adoption of an amendment to the rule to fix the so-called “black hole” issue. ...more
In astronomy, there can be no escape from a black hole. In the world of residential mortgage lending, the CFPB has charted a new course, finally creating an escape from one of TILA/RESPA’s most impracticable rules. On April...more
The Consumer Financial Protection Bureau comes through with a solution to a particularly vexing disclosure rule. Our Financial Services & Products Group shines some light on the new TRID Rule that solves several problems but...more
Amendment Addresses the “Black Hole” Issue - On April 26, 2018, the Consumer Financial Protection Bureau (CFPB or Bureau) finalized an amendment to its TILA-RESPA Integrated Disclosure (TRID) Rule that addresses when...more
On February 14, 2018, the United States House of Representatives passed the TRID Improvement Act of 2017, H.R. 3978, by a vote of 245 to 171. The bill would amend the manner in which title insurance premiums are disclosed...more
The financial services industry — and the consumer financial services marketplace in particular — is experiencing significant innovation. Technology has facilitated the emergence of fintech as a major industry — fundamentally...more