The Consumer Financial Protection Bureau (CFPB) has cranked out more than 2,400 pages of new proposed regulations since July 9th. That is a lot to review in a short period of time. Let’s put this into context. The CFPB had two hours to draft each page starting from the date the Dodd-Frank Act became law. If you give the CFPB the benefit of the doubt and don’t start counting days until July 21, 2011, when […]
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On August 17, 2012 the Consumer Financial Protection Bureau (CFPB) released a 369-page proposal to amend Regulation Z. The amendments involve loan originator compensation. These proposals clarify and expand on existing regulations governing loan originator compensation and qualifications. They also implement new laws, including a restriction on the payment of upfront discount points, origination points, and fees on most mortgage loan transactions. Restriction on Upfront Points and/or Fees The proposed rule requires that, before a […]
On August 15, 2012 the Federal Reserve Board, the Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively, the Agencies) jointly proposed to amend Regulation Z, to implement a Dodd-Frank Act provision requiring appraisals for “higher-risk mortgages.” Comments are due on or before October 15, 2012. The 211-page proposed rule generally defines a “higher-risk mortgage” as a closed-end consumer […]
How refreshing to get a proposal from the CFPB that totals less than 100 pages. On August 15, 2012 the Consumer Financial Protection Bureau (CFPB) published a 58-page release that contains proposed rules to implement a Dodd-Frank Act requirement that amends appraisal rules to help inform mortgage applicants on how a creditor determines a property’s value prior to closing on the mortgage. It will also make it easier for loan applicants to determine if a loan […]