The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank. The adjustments reflect changes in the Consumer Price Index in effect on June 1, 2016 and will take effect January 1, 2017.… Continue Reading
high-cost mortgage
Reduced HOEPA/QM points and fees limits; revisions to Reg Z small creditor/rural area definitions and asset test effective January 1
By Richard J. Andreano, Jr. on
Posted in Mortgages, Regulatory and Enforcement
Since it is unusual for CFPB annual adjustments to result in reduced thresholds, we want to remind blog readers of the reduced HOEPA and QM points and fee limits that will be effective January 1, 2016.
Effective January 1, the lower limits will be:
- The total loan amount thresholds that determine whether a transaction is a high cost mortgage when the points and fees are either 5 percent or 8 percent of such amount will be, respectively, $20,350 and $1,017.
CFPB publishes annual CARD Act, HOEPA and QM adjustments
By Barbara S. Mishkin on
The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank. The adjustments made by the final rule are effective January 1, 2016.
The CARD Act requires the CFPB to calculate annual adjustments of (1) the minimum interest charge threshold that triggers disclosure of the minimum interest charge in credit card applications, solicitations and account opening disclosures, and (2) the fee thresholds for the penalty fees safe harbor. … Continue Reading
CFPB extends deadline for comments on expanded finance charge definition and changes to high-cost mortgage test to offset expansion
By Richard J. Andreano, Jr. on
In July, the CFPB proposed amendments to Regulation Z (TILA) and Regulation X (RESPA) to implement various provisions of the Dodd-Frank Act. Those proposals included an expansion of the definition of “finance charge” to include additional charges, and a new test for determining when a mortgage meets the APR trigger for a “high-cost mortgage” to offset the expanded finance charge. … Continue Reading