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Earlier this month, the CFPB issued a proposal to clarify the application of the Regulation Z prohibition on financing credit insurance premiums (Section 1026.36(i)) to transactions in which credit insurance premiums are charged periodically rather than added as a lump sum at closing.

The proposal, which fell short of industry expectations that the CFPB would clarify that level and levelized premiums are outside the prohibition’s scope, has generated several comment letters urging the CFPB to revise its proposal.… Continue Reading

The CFPB’s proposed changes to the Regulation Z prohibition on financing credit insurance premiums (Section 1026.36(i)) fall short of industry expectations that the CFPB would clarify that level and levelized premiums are outside the prohibition’s scope.  The prohibition was one of the amendments to Regulation Z made by the CFPB’s January 2013 final rule on loan originator compensation. … Continue Reading

The CFPB has issued a final rule delaying the June 1, 2013 effective date of the Regulation Z prohibition on financing credit insurance premiums (Section 1026.36(i)).  The final rule sets January 10, 2014 as the prohibition’s new effective date, which is also the effective date for most of the mortgage-related rules issued by the CFPB in January 2013.  … Continue Reading