Sixteen industry trade groups, including the American Bankers Association, the American Financial Services Association and the Mortgage Bankers Association, have written to Director Cordray urging the CFPB to convene a Small Business Regulatory Enforcement Fairness Act (SBREFA) panel on the proposed ability-to-repay/qualified mortgage rule. As we reported, on May 31, the CFPB reopened the comment period on the proposed rule issued by the Fed.… Continue Reading
SBREFA
SBREFA review process update
By Barbara S. Mishkin on
Posted in CFPB Rulemaking, Regulatory and Enforcement
The CFPB has now convened a second Small Business Regulatory Enforcement Fairness Act (SBREFA) panel. The second panel was asked to provide input on the mortgage servicing rules proposal that the CFPB is developing. (The first panel was convened to consider the proposal the CFPB is developing for integrated TILA and RESPA disclosures and the rules governing those disclosures.)… Continue Reading
Changes to mortgage disclosure rules: CFPB shares some thoughts
By Richard J. Andreano, Jr. on
As we reported last week, the CFPB announced that it was wrapping up testing of its integrated mortgage disclosure prototypes and gearing up for the rulemaking process. Because the CFPB’s rule will have a significant impact on a substantial number of small business entities, the CFPB must convene a small business panel before issuing its proposal as required by the Small Business Regulatory Enforcement Fairness Act (SBREFA).… Continue Reading
“Know before you owe”: goodbye testing; hello SBREFA
By Richard J. Andreano, Jr. on
Posted in Mortgages, Regulatory and Enforcement
The CFPB is conducting this week its final round of testing in its “Know Before You Owe” project. Instead of asking for comments on side-by-side comparisons of prototypes for the same disclosure, the CFPB is asking for comments on one prototype of a RESPA/TILA integrated application disclosure and one prototype of a RESPA/TILA integrated settlement disclosure.… Continue Reading