CFPB, Federal Agencies, State Agencies, and Attorneys General
The CFPB recently issued a request for information (RFI) on the Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure (TRID) rule, the right of rescission under TILA, and reverse mortgages. Comments are due by August 10, 2026.
The RFI is based on the March 2026 Executive Order (EO) 14393 entitled “Promoting Access to Mortgage Credit”.… Continue Reading
On May 12, 2026, we produced a 90-minute webinar in which we explored one of the most important and rapidly developing issues in consumer financial services law: coerced debt and the emerging legislative efforts designed to address it. The webinar has been re-purposed into a two-part podcast series, the first of which was released this past Thursday, June 11th, and the second of which is being released today, Thursday, June 18th.… Continue Reading
In today’s episode of the Consumer Finance Monitor Podcast Show, our host, Ballard Spahr’s Alan Kaplinsky, was joined by colleagues Steven Burt and Melanie Vartabedian to explore a rapidly evolving and increasingly complex area of consumer financial services: residential solar finance.
Building on prior discussions of the broader solar finance landscape, this episode zeroes in on the regulatory and litigation developments that are reshaping the residential solar market in real time.… Continue Reading
The CFPB recently issued a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan (HPML).
Regulation Z, which implements the TILA, generally requires creditors to maintain an escrow account for the payment of taxes and insurance on a first lien HPML.… Continue Reading
Recently, a complaint was filed against loanDepot.Com, LLC (“loanDepot”) in the U.S. District Court for the District of Maryland alleging violations of the Truth in Lending Act (TILA)/Regulation Z loan originator compensation rule (Rule), which applies to closed-end consumer credit transactions secured by a dwelling.
The complaint alleges that loanDepot “unlawfully steered Plaintiffs and those similarly situated to loans with higher rates and fees and further created a system for the falsification of internal forms and federal disclosures to conceal those activities.”… Continue Reading
As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Act), enacted in 2018, directs the CFPB to prescribe regulations that apply Truth in Lending Act (TILA) ability-to-repay (ATR) requirements to Property Assessed Clean Energy (PACE) transactions, and apply the TILA civil liability provisions to violations of the requirements.… Continue Reading
The CFPB recently issued a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan (HPML).
Regulation Z, which implements the TILA, generally requires creditors to maintain an escrow account for the payment of taxes and insurance on a first lien HPML.… Continue Reading
The CFPB has issued a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z under the Truth in Lending Act (TILA) that implement the CARD Act, Home Ownership and Equity Protection Act (HOEPA), and the ability to repay/qualified mortgage provisions of TILA. The adjustments reflect changes in the Consumer Price Index (CPI) in effect on June 1, 2024 and will take effect January 1, 2025.… Continue Reading
The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan (HPML).
Banks, savings associations and credit unions are not subject to HMDA for a calendar year if their assets as of December 31 of the prior calendar year did not exceed an asset threshold.… Continue Reading
The CFPB recently approved an application (Application) from the Independent Community Bankers Association (ICBA) for alternative disclosures under the Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure (TRID) rule for construction-to-permanent loans. The Application is for a Trial Disclosure Program Waiver Template (TDP Waiver Template).… Continue Reading
