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HPML ESCROW EXEMPTION THRESHOLD INCREASED

For 2020 the CFPB amended the official commentary that interprets the requirements of Regulation Z (Truth in Lending) to reflect a change in the asset size threshold for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan.  The exemption threshold is adjusted to $2.202 billion from $2.167 billion.  The revised commentary to regulation Z, Paragraph 1026.35(b)(2)(iii)-1(iii)(E), includes the amended threshold stating: Under section 1026.35(b)(2)(iii)(C), […]

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TRID CONSTRUCTION LOAN GUIDES

On Wednesday, Dec. 18, 2019, the Consumer Financial Protection Bureau (CFPB) published two guides on disclosing construction-only and construction-permanent loans with examples based on common questions received by the Bureau. The Combined Guide  provides guidance for disclosing the phases together and the Separate Guide  provides guidance for disclosing the phases separately. Alternate Headline: CFPB Publishes Inadequate TRID Construction Loan Guidance More Than Four Years After the Effective Date Have you ever heard the old saying , “a day late […]

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CFPB PUBLISHES FALL 2019 UNIFIED AGENDA

Recently the Consumer Financial Protection Bureau (CFPB) published its Fall 2019 rulemaking agenda. The agenda identifies the regulatory matters that the CFPB reasonably anticipates having under consideration during the period from October 1, 2019 to September 30, 2020. The following summaries a few key topics: Proposed Fair Debt Collection Rule (Regulation F) – The CFPB proposed Regulation F in May 2019.  Now the CFPB is testing consumer disclosures related to time-barred debt and, after testing, […]

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CFPB COMMENCES TRID ASSESSMENT

On November 20 the Consumer Financial Protection Bureau (CFPB) announced that it commencing an assessment of its TRID (Truth in Lending Act and Real Estate Settlement Procedures Act Integrated Disclosure) rules. The CFPB intends to address the TRID Rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors.  The public is invited to comment on the feasibility and effectiveness of […]

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CFPB PUBLISHES ADDITIONAL THRESHOLDS FOR REGULATIONS M AND Z

On October 30, 2019 the CFPB published final rules in the Federal Register adjusting exemptions thresholds in Regulations Z and M for the year 2020. Comment 35(c)(2)(ii)-3.vii will be added to the Official Interpretations of § 1026.35 of Regulation Z to increase the threshold amount to $27,200 for the exemption from the special appraisal requirements for higher-priced mortgage loans. Comment 3(b)-3.xi will be added to the Official Interpretations of § 1026.3 of Regulation Z to increase the threshold amount […]

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