Bank Law Monitor

Bank Law Monitor

A Legal Blog for the Financial Services Industry

Category Archives: TILA/RESPA

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Citing Operational Challenges, CFPB May ReWrite TRID

Posted in CFPB, Compliance Resources, Mortgage Servicing, Regulatory Developments, TILA/RESPA, Trending News
Today, the CFPB issued a letter to various industry trade groups, including the Mortgage Bankers Association, the American Bankers Association, and the Independent Community Bankers of America,  acknowledging that the implementation of the “Know Before You Owe” rule  (otherwise known as “TRID”) poses many “operational challenges.”   Many financial institutions and industry participants do not have… Continue Reading

CFPB Director’s Statement About TRID Liability Does Not Resolve Uncertainty in the Secondary Market

Posted in CFPB, TILA/RESPA
Since October 3, 2015, which was the effective date of the TILA-RESPA Integrated Disclosure Rules (TRID), banks and members of the mortgage industry have continued to work hard to implement TRID. But for those who have attempted to seek liquidity by selling mortgage loans in the secondary market, the transition to TRID has not been… Continue Reading

Mortgage Loan Rate Locks: A New Risk Environment Under TRID

Posted in CFPB, Mortgage Servicing, Regulatory Developments, TILA/RESPA
The Consumer Finance Protection Bureau’s (the “CFPB”) amendments to the 2013 TILA-RESPA Integrated Disclosure Rule (“TRID”) will become effective on October 3, 2015.  The amendment extends the timing requirement for revised disclosures when consumers of mortgage loans lock a rate or extend a rate lock after the Loan Estimate is provided.  Lenders can now provide… Continue Reading

Updated Compliance Resources for the TILA-RESPA Integrated Disclosure Rule

Posted in CFPB, Compliance Resources, Mortgage Servicing, Regulatory Developments, TILA/RESPA, Trending News
As many of you know, the effective date of the TILA-RESPA Final Rule and the related TILA-RESPA Amendments has been delayed to October 3, 2015. Please take note of the following updates from the CFPB: Freddie Mac and Fannie Mae Data Standards Freddie Mac and Fannie Mae have released a common industry dataset, called the… Continue Reading

CFPB Expands Its Jurisdiction to Include Nonbank Auto Finance Companies

Posted in Auto Finance, CFPB, TILA/RESPA, UDAAP, Uncategorized
On June 10, 2015, the CFPB published a rule that will allow the agency to supervise nonbank auto finance companies that make, acquire or refinance 10,000 or more loans or leases a year. This rule was originally proposed in September 2014 and is the fifth in a series of rulemakings to define larger participants of markets… Continue Reading

New Integrated Loan Disclosure Requirements Become Effective August 1, 2015

Posted in TILA/RESPA, Trending News
On June 3, 2015, the Consumer Financial Protection Bureau (CFPB) issued a statement reminding mortgage lenders that the new integrated loan disclosures required by Dodd-Frank become effective August 1, 2015. Because the TILA/RESPA Integrated Disclosure Rule, or TRID Rule, requires lenders to make substantial changes to their internal procedures for mortgage originations, the industry had… Continue Reading

Spotlight on TILA’s Duty to Provide Timely Mortgage Payoff Statements

Posted in CFPB, Mortgage Servicing, Regulatory Developments, TILA/RESPA
87787269_XS[1]Given the growing complexity of the mortgage servicing rules faced by both bank and non-bank mortgage servicers, it is worthwhile to shine a spotlight on some rules which at first glance seem fairly straight forward, but upon scrutiny, require more analysis. As previously discussed on this blog, the CFPB amended the Truth in Lending Act (TILA)… Continue Reading

Mortgage Industry Continues to Face New Regulatory Proposals in 2015

Posted in Basel III, CFPB, Mortgage Servicing, Regulatory Developments, TILA/RESPA
CFPB Proposes to Give Relief to Small Lenders        On January 29, 2015, in response to comments from industry groups and stakeholders, the CFPB proposed amendments to certain mortgage rules that were issued in 2013.  The CFPB will take comments until March 30, 2015 on these proposed rules.  The proposed rule expands the CFPB’s definition… Continue Reading

CFPB: Big Changes to the Mortgage Servicing Rules

Posted in CFPB, Mortgage Servicing, Regulatory Developments, TILA/RESPA
On October 22, 2014, the CFPB finalized amendments granting nonprofit small servicers an exemption from new mortgage servicing rules. These mortgage servicing rules are part of several rules regulating mortgages, including the Ability-to-Repay rules, that went into effect on January 10, 2014.   The servicing related changes impacts nine key areas: Periodic billing statements Interest rate… Continue Reading

Welcome to Bank Law Monitor: A Legal Blog for the Financial Services Industry

Posted in Auto Finance, CFPB, Compliance Resources, Credit Cards, Debt Collection, Marijuana, Mortgage Servicing, Overdrafts, Regulation AB, Regulatory Developments, TILA/RESPA, Trending News, UDAAP
Welcome! Graham & Dunn’s Financial Services team is pleased to announce the launch of Bank Law Monitor, a legal blog for the financial services industry. Bank Law Monitor will analyze regulatory developments, report on significant news and market trends, and monitor upcoming regulatory changes that impact the financial services industry. Our goal is to help… Continue Reading