MORE REGULATION Z (TIL) AND REGULATION X (RESPA)

The biggest big news on Monday July 9, 2013 was the 1,099 page proposal to combine TIL and RESPA forms. The other big news on Monday was the 293 page proposal to amend the Truth in Lending Act by expanding the types of mortgage loans that are subject to the protections of the Home Ownership and Equity Protection Act of 1994 (HOEPA), by revising and expanding the triggers for coverage under HOEPA, and by imposing additional restrictions on HOEPA mortgage loans, including a pre-loan counseling requirement. The Dodd-Frank Act also amends the Truth in Lending Act and the Real Estate Settlement Procedures Act by imposing certain other requirements related to homeownership counseling. Comments must be received on or before September 7, 2012.

A copy of the High-Cost Mortgage and Homeownership Counseling proposal is available here.

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