Archive

CFPB PUBLISHES THE FINAL FINAL ABILITY-TO-REPAY AND QUALIFIED MORTGAGE STANDARDS

On May 29, 2013 the Consumer Financial Protection Bureau (CFPB) published a final2 rule to amend a final rule published in January 2013 that generally prohibits a creditor from making a mortgage loan unless the creditor determines that the consumer will have the ability to repay the loan.. The final2 rule provides an exemption to these requirements for creditors with certain designations, loans pursuant to certain programs, certain nonprofit creditors, and mortgage loans made in connection […]

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CFPB PUBLISHES FINAL FINAL RULE AMENDING THE PROHIBITION ON FINANCING CREDIT INSURANCE PREMIUMS

On May 29, 2013 the Consumer Financial Protection Bureau (CFPB) published a final2 rule that amends Regulation Z to delay the June 1, 2013 effective date of a prohibition on creditors financing credit insurance premiums in connection with certain consumer credit transactions secured by a dwelling. The CFPB is delaying the effective date until January 10, 2014, to permit the Bureau to clarify, before the provision takes effect, its applicability to transactions other than those […]

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CFPB PUBLISHES THE FINAL FINAL ESCROW RULE (WE HOPE.)

Recently the Consumer Financial Protection Bureau (CFPB) published what we hope is the final final revised rule for escrows on higher-priced mortgage loans (HPMLs). This final final rule amends the final rule the CFPB issued in January 2013. The January final rule lengthened the time for which a mandatory escrow account established for a higher-priced mortgage loan (HPML) must be maintained. The rule also established an exemption from the escrow requirement for certain creditors that operate predominantly […]

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CFPB PUBLISHES FINAL LIST OF RURAL AND UNDERSERVED COUNTIES

Recently the Consumer Financial Protection Bureau (CFPB) published the final list of counties designated as rural or underserved.  This final list is identical to the preliminary list published on March 12. The list is used to determine if escrows are required for certain higher-priced mortgage loans. Escrow rules for higher-priced mortgage loans (HPMLs) are scheduled to go into effect  on June 1, 2013. The rules require creditors to create and maintain escrow accounts for a […]

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CFPB AMEND CREDIT CARD ACT RULE FOR STAY-AT-HOME SPOUSES AND PARTNERS

On April 29, 2013 the Consumer Financial Protection Bureau published an 86-page final rule to amend Regulation Z.  The final rule has four main elements: First, the final rule generally removes references to an independent ability-to-pay standard from Section 1026.51(a)(1) and associated commentary. As a result, card issuers are no longer required to consider whether consumers age 21 or older have an independent ability to pay; instead, card issuers are now required by Regulation Z […]

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