As we have previously reported, in October 2015 the CFPB adopted significant revisions to the Home Mortgage Disclosure Act (HMDA) rule, most of which become effective January 1, 2018. Among the revisions, the reporting of home equity lines of credit under HMDA, which currently is voluntary, will become mandatory for both depository institutions and non-depository institutions that originated at least 100 home equity lines of credit in each of the two preceding calendar years.… Continue Reading
CFPB issues temporary exemption for new mortgage disclosures
On November 16, the CFPB adopted a temporary exemption for certain mortgage disclosure requirements added by the Dodd-Frank Act to allow the disclosures to be implemented along with the proposal to integrate the Real Estate Settlement Procedures Act and Truth in Lending Act disclosures. Without the temporary exemption, industry would have been required to begin providing the new disclosures as of January 21, 2013.… Continue Reading
FTC staff comments on CFPB’s integrated TILA/RESPA mortgage disclosures proposal
In July, the CFPB released its long-awaited nearly 1,100-page proposal consolidating the application and closing disclosures required by TILA and RESPA for mortgage loan transactions. Comments on the proposed integrated disclosures are due by November 6.
On September 25, the staff of the Federal Trade Commission’s Bureau of Consumer Protection, Bureau of Economics and Office of Policy Planning submitted its comments on the CFPB’s proposal. … Continue Reading