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
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,
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
There are not a lot of changes with Fair Lending right now, but the topic is red hot. Both HUD and the Department of Justice have taken recent action, and much more is coming. HUD Settlement Agreement On December 21, 2010 the U.S. Department of Housing and Urban Development (HUD), the Metropolitan St. Louis Equal Housing Opportunity Council (EHOC), and First National Bank of St. Louis entered into an agreement that requires the bank to
Apparently examiners have recently slammed a few lenders for the failure deliver a GFE or for the failure to provide the GFE within the required three business day period. The penalty examiners are imposing for this RESPA violation is a refund of all fees imposed in the transaction. Yes; you read that correctly, a refund of all fees. Some bankers are asking what happened to the 10% tolerance applicable to certain items on the GFE.