CFPB RELEASES COMBINED TIL/RESPA FORM PROPOSAL

Earlier today the Consumer Financial Protection Bureau (CFPB) published the first of three proposed revisions to Regulation Z that are expected this month. The 1,099 page release proposes model forms and new rules for mortgage loans. The proposal combines Truth in Lending and RESPA disclosures into a single document
The comment period expires, for the most part, on November 6, 2012; however the comment period for rules on changes in the calculation of the finance charge and the APR and the delayed effective date for certain disclosures required by the Dodd-Frank Act expires on September 7, 2012. The rule is expected to be finalized no later than January 21, 2013, with an effective date of no later than January 21, 2014. A copy of the full release is available at https://www.jackscomplianceresource.com/files/cfpb_proposed-rule_integrated-mortgage-disclosures.pdf.
Members of our Compliance Masters Group have already received a blog article informing them of the proposed rule. At our next meeting on July 13, 2012 they will receive a detailed review of the proposal and a directors/senior management update sheet ready to present to the board at its next meeting. Once the rules are final they will receive a risk assessment, updates to policies and procedures and front line training materials.

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