Archive

WHAT’S UP WITH ESCROWS

On February 23, 2011 the Federal Reserve Board issued a final rule and requested public comment on a second rule under Regulation Z to revise the escrow account requirements for certain home mortgage loans. The revisions to the regulation, which implements the Truth in Lending Act (TILA), are being made pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act. The final rule implements a provision of the Dodd-Frank Act that increases the annual […]

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MASSIVE REGULATION Z RULES ARE SHELVED

Recently the Federal Reserve Board announced that it does not expect to finalize three pending rulemakings under Regulation Z prior to the transfer of authority for such rulemakings to the Consumer Financial Protection Bureau (CFPB). The proposed rules were massive. They would have changed all of the rules regarding the disclosures for mortgage loans, both open-end (HELOCs) and closed-end. But we haven’t seen the last of these proposals; they will be revived by the new […]

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WHICH WAY IS THE WIND BLOWING TODAY?

Some days the wind blows hot, other days it is cold. Some days the wind is hurricane force, others it s gentle breeze. Some days it blows out of the north, others days it blows from another point of the compass. Recently the FDIC announced the hiring of additional key leadership staff for the Division of Depositor and Consumer Protection (DCP). The FDIC Board of Directors approved the establishment of the new organizations in August, […]

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HMDA – WHAT IS A REFINANCE

Recently I got a question from a banker. “We have received conflicting information on what qualifies as a refinance. If we have the borrower sign a new note but keep the same note number, should we report the transaction as a refinance?” That’s a great question, but not so easy to answer. The failure to adequately define the term “refinance” is one of the Federal Reserve Board’s biggest screw-ups. We can only hope that when […]

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