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On September 21, 2015 the Consumer Financial Protection Bureau approved a final rule amending Regulation Z. The final rule revises the CFPB’s regulatory definitions of small creditor, and rural and underserved areas, for purposes of certain special provisions and exemptions from various requirements provided to certain small creditors under the Bureau’s mortgage rules.
The final rule specifically addresses:
- Escrow requirements for higher-priced mortgage loans; and
- Ability-to-repay/qualified mortgage requirements.
The 144-page final rule is generally effective on January 1, 2016.
This two-hour webinar explains the new rules and the actions needed to comply with the new requirements and to take advantage of the new opportunities.
Upon completion of this program, participants understand how the final rule:
- Raises the loan origination volume test for Small Creditors in two different ways and adjusts the $2 billion asset limit in manner that is not favorable for some creditors.
- Adjusts the time period used in determining whether a creditor is operating predominantly in rural or underserved areas from any of the three preceding calendar years to the preceding calendar year.
- Amends the current exemption under § 1026.35(b)(2)(iii)(D)(1) provided to small creditors that operate predominantly in rural or underserved areas from the requirement for the establishment of escrow accounts for higher-priced mortgage loans.
- Expands the definition of “rural” by adding census blocks that are not in an urban area as defined by the U.S. Census Bureau to the current county-based definition.
- Extends the current two-year transition period, which allows certain small creditors to make balloon-payment qualified mortgages (§ 1026.43(e)(6)) and balloon-payment high-cost mortgages (§ 1026.32(d)(1)(ii)(C)), regardless of whether they operate predominantly in rural or underserved areas.
The program is designed for compliance officers, auditors, lending department management, loan operations personnel, loan officers, loan originators and others involved in originating or servicing mortgage loans.