It appears a flat loan origination fee requirement wasn’t such a good idea after all.  That’s the conclusion the CFPB came to in its proposal issued on August 17 to integrate the Dodd-Frank mortgage loan originator compensation provisions with the existing Regulation Z provisions, and implement Dodd-Frank loan originator requirements. 

We have prepared a legal alert that discusses the proposal and how it differs from the CFPB’s description in May of the issues it was then considering.… Continue Reading