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In his remarks at the Mortgage Bankers Association’s annual meeting in Boston on October 25, Director Cordray signaled that mortgage servicing will continue to be a focus of CFPB supervisory and enforcement activity, with the CFPB taking a rigorous approach to compliance.  

While noting that the CFPB has seen “some progress” in compliance with CFPB mortgage servicing rules,” most notably efforts by certain servicers to adequately staff up effective compliance management programs,”  Director Cordray stated that “many troubling issues persist.” … Continue Reading

The FDIC has revised its interagency examination procedures to reflect the requirements of the TILA/RESPA integrated disclosures (TRID) rule.  The CFPB has issued a proposal to postpone the TRID rule’s effective date from August 1 to October 3, 2015.

The revised procedures also reflect the following amendments to other provisions of TILA Regulation Z and RESPA Regulation X:

  • the alternative definition of the term “small servicer” for certain nonprofit entities in the mortgage servicing rules
  • the provisions in the ability-to-repay/qualified mortgage rule that give creditors or assignees meeting certain requirements a limited period of time in which to review a transaction and “cure” excess points and fees for purposes of maintaining QM status
  • additional exempt transactions under the appraisal rule for higher-priced mortgage loans

In May 2015, the OCC released revisions to the TILA and RESPA chapters of its examination manual for consumer compliance exams to incorporate the requirements of the TRID rule.… Continue Reading

While not agreeing to the grace period from enforcement sought by lawmakers and industry, Director Cordray stated in a letter sent yesterday to members of Congress that the CFPB “will be sensitive to the progress made by those entities that have squarely focused on making good-faith efforts to come into compliance with the [TILA/RESPA Integrated Disclosure (TRID)] Rule on time.” … Continue Reading

The CFPB has revised the chapters of its Supervision and Examination Manual specific to TILA and RESPA, incorporating the TILA/RESPA integrated disclosures (TRID) requirements that are set to take effect on August 1, 2015.  These chapters replace versions of the TILA and RESPA procedures released on November 27, 2013.

As is the case for most statute-specific portions of the Manual, the TILA and RESPA chapters each contain two parts:  a narrative portion outlining the substantive requirements and restrictions of the law and its implementing regulation, and a detailed examination checklist. … Continue Reading

A group of 17 trade associations and organizations have written to the CFPB seeking a grace period for enforcement of  the TILA-RESPA Integrated Disclosure (TRID) rule which becomes effective on August 1, 2015.

In their letter, the groups seek written guidance from the CFPB on various situations not addressed by the TRID rule and ask the CFPB to announce and implement a “restrained enforcement and liability” or “grace period” for those seeking to comply in good faith following the provision of such guidance after August 1 through the end of 2015. … Continue Reading

On Tuesday, January 20, the CFPB promulgated its first final rule of 2015, a series of minor amendments to the TILA/RESPA integrated disclosures (TRID) rule.  The substantive changes to the TRID rule are (1) an extension of the time period to issue a revised Loan Estimate when an interest rate moves from floating to locked, and (2) a provision for disclosing that a creditor has reserved its right to issue a revised Loan Estimate for loans funding new construction.… Continue Reading

On October 1, 2014, the CFPB staff and Federal Reserve Board co-hosted a webinar that addressed questions about the Final TILA-RESPA Integrated Disclosure Rule that will be effective for applications received by creditors or mortgage brokers on or after August 1, 2015.  The webinar focused on the Loan Estimate and addressed specific questions regarding the content of the Loan Estimate form that relate to corresponding provisions of the Closing Disclosure.  … Continue Reading