The CFPB has issued several more Small Entity Compliance Guides on its mortgage-related rules. In addition to its guide on the ability-to-repay and qualified mortgage rule, the CFPB has now issued Small Entity Compliance Guides on the 2013 HOEPA rule, escrow rule for higher-priced mortgages, ECOA valuations rule, and TILA higher-priced mortgages appraisal rule.
Each of the guides indicates that it is intended to provide a summary of the underlying rule that “highlights issues” that small creditors, and their partners or others that work with them, “might find helpful to consider when implementing the rule.” Each guide also cautions that it is not a substitute for the underlying rule.