Archive

HMDA PROPOSAL PUBLISHED

On July 24, 2104 the Consumer Financial Protection Bureau (CFPB) published proposed rules to implement changes to the Home Mortgage Disclosure Act (HMDA). Some of the proposed changes are mandated by the Dodd-Frank Act, others are part of a CFPB effort to modernize and streamline regulations. Comments on the 572-page proposal are due on or before October 22, 2014. Coverage There had been speculation that coverage would be expanded to all mortgage lenders that originated […]

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HOMEOWNERSHIP COUNSELING POLL

HOMEOWNERSHIP COUNSELING POLL Compliance Masters Group July 18, 2014   A recent poll of our Compliance Master Group members centered on the issue of homeownership counseling rules. There were no huge surprises. We got a lot of confirmation of what we expected to see: Providing the list of counseling organizations is not a significant burden; The potential burden on consumers is high, but unrealized, since most of our members have few, if any, transactions subject […]

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ABILITY TO REPAY – SUCCESSORS-IN-INTEREST

On July 11, 2014 the Consumer Financial Protection Bureau (CFPB) released a 10-page rule that clarifies that where a successor-in-interest (successor) who has previously acquired title to a dwelling agrees to be added as obligor or substituted for the existing obligor on a consumer credit transaction secured by that dwelling, the creditor’s written acknowledgement of the successor as obligor is not subject to the Ability-to-Repay Rule (ATR Rule), § 1026.43, because such a transaction does […]

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EQUAL TREATMENT FOR SAME-SEX MARRIED COUPLES

On June 26, 2013, in United States v. Windsor, the U.S. Supreme Court struck down Section 3 of the Defense of Marriage Act as unconstitutional. The Consumer Financial Protection Bureau (CFPB) has noted on its blog that the decision has important consequences for its work. In order to fully implement the decision, the CFPB has taken steps to clarify how the decision affects the rules for which the agency is responsible. Recently, CFPB Director Cordray issued a […]

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