CFPB Adjusts Mortgage Rules to Ensure Credit in Underserved Populations

The Consumer Financial Protection Bureau (CFPB) finalized minor adjustments to its mortgage rules which will help nonprofit organizations ensure access to credit and servicing for underserved populations.


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CFPB Releases Readiness Guide

The Consumer Financial Protection Bureau has released an updated rules Readiness Guide that includes the TILA-RESPA Integrated Disclosure.

“This update offers financial institutions and other industry participants valuable guidance on how to evaluate their readiness for complying with the mortgage rule changes,” the bureau said in a press release.

The updated guide addresses changes made to Regulation Z and Regualtion X,  which cover the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA).

Click here to view the guide: Readiness Guide here.



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CFPB Takes First Enforcement Action Under New Mortgage Servicing Rules

On September 29th the CFPB issued its first fine under the new mortgage servicing rules.  An order was issued against Flagstar Bank for not acting in a timely manner in reviewing loss mitigation applications resulting in borrower’s losing their homes.  Flagstar was ordered to pay $27.5 million to consumers and an additional $10 million fine to the CFPB.  See Director Cordray’s remarks below.

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Who will prepare the Closing Disclosure Form?

While the title industry is preparing to implement the new rules and regulations from the CFPB’s Final Rule one question that continuously comes up is…. Who will prepare the closing disclosure form?  While no one yet knows the answer, Wells Fargo recently issued a statement laying out their plans to complete and deliver the final form. See Wells Fargo’s statement below:

communication to settlement agents

While Wells Fargo has decided on their plans for the closing disclosure form settlement agents will still need to work with their individual lenders on how they will handle the preparation and delivery of the final closing disclosure form.

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Can the Closing Disclosure Form be used prior to August 1, 2015?

That is the most frequently asked question among title and settlement agent regarding the August 1, 2015 implementation date for Integrated Mortgage Closing Disclosure Form (CDF).  Can a lender/creditor require a settlement agent to use the form prior to August 1, 2015?  The CFPB addressed this question their Compliance Guide.

Can a creditor use the new Integrated Disclosures for applications received before August 1, 2015?

No. For transactions where the application is received prior to August 1, 2015, creditors will still need to follow the current disclosure requirements under Regulations X and Z, and use the existing forms (Truth-in-Lending disclosures, GFE, HUD-1).

To view the entire Compliance Guide click below:


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CFPB Releases RESPA-TILA Disclosure Update and Timing Example

On Monday, September 8th, the CFPB released updated versions of the Small Entity Compliance Guide for the TILA-RESPA Integrated Disclosure Rule.

The CFPB also included a timeline that helps illustrate the process and timing of disclosures under the TILA-RESPA Integrated Disclosure Rule.

View the updated guides and timeline

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Is Owner’s Title Insurance Subject to Tolerance?

On August 26 the Federal Reserve held a webinar addressing some FAQ’s from the CFPB’s TILA-RESPA Integrated Disclosure Rule.  One hot topic covered was whether or not owner’s title insurance is subject to the 10% tolerance rule.  Below is a summary from the webinar:

Q: Is owner’s title insurance not required by the creditor subject to the 10% cumulative tolerance?

No. Owner’s title insurance that is not required by the creditor is not subject to the 10% cumulative tolerance.

Owner’s title insurance is not a charge that is assigned to a particular tolerance category. If owner’s title insurance is not required by the creditor and is disclosed as an optional service, it is not subject to any tolerance violations, even if paid to an affiliate of the creditor.



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