Real Estate Settlement Procedures Act

The CFPB has announced the settlement of an enforcement action in which it was alleged that two affiliated business arrangements (ABAs) violated Section 8 of the Real Estate Settlement Procedures Act.  

The arrangements involved two mortgage origination companies created by a Texas homebuilder who owned one company  together with a bank and the other company

The CFPB seems to be feeling defensive about the length of its recently-issued proposal  that combines the separate application disclosures and the separate closing disclosures required by the Real Estate Settlement Procedures Act and Truth in Lending Act into a single application disclosure and a single closing disclosure. 

The CFPB has put a new post

On July 9, 2012 the CFPB issued two significant proposed mortgage-related rulemakings under The Dodd-Frank Wall Street Reform and Consumer Protection Act.

One proposal provides for the combination of the separate application disclosures and the separate closing disclosures required by the Real Estate Settlement Procedures Act and Truth in Lending Act into a single application