Pennsylvania has one of the most active Attorney General offices when it comes to bringing cases against financial companies. This is due to the office’s Consumer Financial Protection Unit, which was formed by Attorney General Josh Shapiro in 2017 because of the expectation that the CFPB would become less potent in protecting consumers. The Unit

On August 26, 2014, the CFPB staff and Federal Reserve Board co-hosted a webinar and addressed questions about the final TILA-RESPA Integrated Disclosures Rule that will be effective for applications received by creditors or mortgage brokers on or after August 1, 2015.  The webinar is the second in a planned series intended to address the new rule.  In the initial webinar the CFPB staff provided a basic overview of the final rule and new disclosures that we have previously covered.

According to the CFPB staff, this webinar and the ones that will follow will be in the format of a spoken Q&A to answer questions that have been posed to the CFPB.  Although the CFPB staff does not plan to issue written Q&A, the staff believes this approach will help facilitate clear guidance on the new rules in an accessible way.  Industry members, however, would prefer written guidance.  Note that the American Bankers Association (ABA) has released a transcript of the CFPB’s webinar that is available to ABA members.

During the remarks, the CFPB staff announced that the CFPB will soon release additional guidance material on its website, including a timing calendar to illustrate the various timing requirements under the new rule.  In addition, the next webinar in the series is tentatively scheduled for October 1, 2014, and will cover Loan Estimate and Closing Disclosure content questions.

Below is a summary of various answers to questions provided by the CFPB staff.  The topics covered include: (1) the receipt of an application, (2) whether new disclosures will be required for assumptions, (3) record retention, (4) the tolerance applicable to owner’s title insurance, and (5) the timing for the initial and revised  Loan Estimates. 
Continue Reading CFPB Answers FAQ on the TILA-RESPA Integrated Disclosures Rule

Deepak Gupta, who was recently Senior Counsel in the Consumer Financial Protection Bureau, will join attorneys from Ballard Spahr’s Consumer Financial Services Group in a November 21 webinar about the CFPB’s amicus program. The webinar, The CFPB’s Amicus Program: Its Implications and Potential Impact, will focus on the program from both industry and consumer