Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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FDIC revises examination procedures to incorporate TILA/RESPA integrated disclosures

The FDIC has revised its interagency examination procedures to reflect the requirements of the TILA/RESPA integrated disclosures (TRID) rule. The CFPB has issued a proposal to postpone the TRID rule’s effective date from...more

7/2/2015 - CFPB Examination Procedures FDIC Industry Examinations TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB blinks on TRID rule effective date

CFPB Director Cordray issued a statement yesterday afternoon indicating that the CFPB will propose to delay the effective date of the TILA/RESPA Integrated Disclosure (TRID) rule until October 1, 2015. The CFPB has previously...more

6/19/2015 - Banking Sector CFPB Delays Mortgage Lenders TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB takes aim (again) at loan originator compensation

Two days after announcing a proposed consent order with a mortgage company and its CEO to settle charges that the company paid bonuses and higher commissions to loan officers in violation of the Regulation Z loan originator...more

6/10/2015 - C-Suite Executives CFPB Consent Order Loan Originator Compensation Rule Mortgage Lenders Mortgage Loan Originators Regulation Z Sales Commissions

CFPB provides breathing room on compliance with TILA/RESPA integrated disclosure rule but misses mark in waiting period guidance

While not agreeing to the grace period from enforcement sought by lawmakers and industry, Director Cordray stated in a letter sent yesterday to members of Congress that the CFPB “will be sensitive to the progress made by...more

6/5/2015 - Banking Sector CFPB Financial Institutions Grace Period Mortgage Lenders Regulation Z Richard Cordray TILA-RESPA Integrated Disclosure Rule (TRID)

Shelby Draft Regulatory Relief Bill Addresses Various Residential Mortgage Issues

Senator Richard Shelby (R-AL) released a draft of a regulatory reform bill titled “The Financial Regulatory Improvement Act of 2015” on May 12, 2015. The draft bill addresses various residential mortgage lending issues...more

6/3/2015 - CFPB HMDA Mortgage Lenders Mortgage Loan Originators Proposed Legislation RESPA Safe Harbors TILA TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB “Final” TRID Webinar

The CFPB staff held a “final” webinar on May 26, 2015, to address the Truth in Lending Act/Real Estate Settlement Procedures Act Integrated Disclosure (TRID) rule that becomes effective on August 1, 2015. Presumably the...more

6/1/2015 - CFPB Homeowners Mortgage Lenders Real Estate Market RESPA TILA TILA-RESPA Integrated Disclosure Rule (TRID) Title Companies Webinar

Does Director Cordray Fully Appreciate the Implications of the TRID Rule?

Statements made by CFPB Director Richard Cordray to the National Association of Realtors on May 12, 2015, suggest that the Director may not fully appreciate the implications of the TILA/RESPA Integrated Disclosure (TRID) rule...more

5/29/2015 - CFPB Closing Documents Financial Institutions Lending Real Estate Market RESPA TILA TILA-RESPA Integrated Disclosure Rule (TRID)

Federal Agencies Issue Final Rule on Standards for Appraisal Management Companies

The CFPB along with five other federal agencies have issued a final rule that establishes minimum state registration and substantive requirements for appraisal management companies (AMCs), as required by Section 1473 of the...more

5/20/2015 - Appraisal Management Companies Banking Sector CFPB Dodd-Frank FFIEC Final Rules

Shelby Draft Regulatory Relief Bill Addresses Various Residential Mortgage Issues

On May 12, 2015 Senator Richard Shelby (R-AL) released a draft of a regulatory reform bill entitled the Financial Regulatory Improvement Act of 2015. The draft bill addresses various residential mortgage lending issues, a...more

5/18/2015 - CFPB Integrated Disclosures Mortgage Lenders Mortgages Regulatory Reform RESPA TILA TILA-RESPA Integrated Disclosure Rule (TRID)

Does Director Cordray fully appreciate the implications of the TRID rule?

Statements made by CFPB Director Cordray to the National Association of Realtors on May 12, 2015 suggest that the Director may not fully appreciate the implications of the TILA/RESPA Integrated Disclosure (TRID) rule that is...more

5/14/2015 - CFPB Integrated Disclosures National Association of Realtors RESPA Richard Cordray TILA TILA-RESPA Integrated Disclosure Rule (TRID)

Federal agencies issue final rule on standards for appraisal management companies

The CFPB along with five other federal agencies have issued a final rule that establishes minimum state registration and substantive requirements for appraisal management companies (AMCs), as required by Section 1473 of the...more

5/7/2015 - Appraisal Management Companies CFPB Depository Institutions Dodd-Frank Final Rules Registration Requirement

The CFPB Announces Final Diversity Standards under Dodd-Frank Section 342 Are Completed

On April 29, 2015, the Office of Minority and Women Inclusion (OMWI) of the Consumer Financial Protection Bureau (CFPB or Bureau) released its third Annual Report for 2014, as mandated by Section 342(e) of the Dodd-Frank Act...more

5/6/2015 - CFPB Diversity Dodd-Frank Federal Contractors OMWI

CFPB Issues Final Rule on Homeownership Counseling Requirements

The CFPB has issued a final rule to assist lender compliance with RESPA and TILA homeownership counseling requirements. Under RESPA, a lender must provide applicants for a federally related mortgage loan with a list of...more

5/1/2015 - CFPB Consumer Lenders Final Rules Homeowners Mortgage Counselor Mortgage Lenders RESPA TILA

CFPB Targets Another Mortgage Lender for Deceptive Advertising

The CFPB has announced the settlement of an enforcement action against a California-based mortgage lender for alleged deceptive advertising practices, including the use of advertisements that the CFPB claimed falsely led...more

4/21/2015 - Advertising CFPB Civil Monetary Penalty Consent Order Enforcement Actions False Advertising Military Service Members Mortgage Lenders Mortgages Popular Regulation N TILA Veterans Administration

CFPB issues final rule on homeownership counseling requirements

The CFPB has issued a final rule to assist lender compliance with RESPA and TILA homeownership counseling requirements. Under RESPA, a lender must provide applicants for a federally related mortgage loan with a list of...more

4/16/2015 - CFPB Final Rules Financial Education Initiatives Mortgage Lenders RESPA TILA

Senate Banking Committee to hold April 16 hearing on mortgage credit availability

On April 16, 2015, the Senate Committee on Banking, Housing and Urban Affairs will conduct a hearing entitled, “Regulatory Burdens to Obtaining Mortgage Credit.” The witnesses scheduled to appear are...more

4/14/2015 - CFPB Congressional Investigations & Hearings Mortgage Lenders Mortgages Senate Banking Committee

CFPB targets another mortgage lender for deceptive advertising

The CFPB has announced the settlement of an enforcement action against a California-based mortgage lender for alleged deceptive advertising practices, including the use of advertisements that the CFPB claimed falsely led...more

4/10/2015 - Advertising CFPA CFPB Consent Order Enforcement Actions Mortgage Lenders Regulation N TILA Unfair or Deceptive Trade Practices

CFPB updates home buying information booklet

The CFPB has issued an updated version of the home buying information booklet (also known as the special information or settlement cost booklet) required under RESPA and TILA. The new booklet is entitled “Your home loan...more

4/2/2015 - CFPB Home Buyer Mortgages RESPA TILA

Trade groups seek grace period for TILA/RESPA integrated disclosure rule

A group of 17 trade associations and organizations have written to the CFPB seeking a grace period for enforcement of the TILA-RESPA Integrated Disclosure (TRID) rule which becomes effective on August 1, 2015. In their...more

3/23/2015 - CFPB Grace Period Integrated Disclosures RESPA TILA Trade Associations

CFPB takes action on misleading advertisements

Late last week, on February 12, the CFPB announced actions against three mortgage companies for alleged violations of Regulation N, the Mortgage Acts and Practices Advertising Rule. Among other restrictions, Regulation N bars...more

2/18/2015 - Advertising CFPB Consumer Lenders False Advertising FTC Government Agencies Misrepresentation Mortgage Lenders Popular Regulation N

CFPB proposes amendments to “small creditor,” “rural” exemptions

On January 29, the CFPB proposed amendments to the portions of Regulation Z governing mortgages made by small creditors. In the same notice, the CFPB also proposed amendments to Regulation Z’s definition of the term “rural,”...more

2/4/2015 - CFPB Mortgages Proposed Amendments Regulation Z Small Credit Institutions

CFPB Report Explores Consumers’ Mortgage Shopping Experience

In a report released on January 13, 2015, the Consumer Financial Protection Bureau announced that nearly half of consumers do not shop among multiple lenders before applying for a mortgage loan. Even fewer—about one of every...more

1/26/2015 - CFPB Consumer Financial Products FHFA Information Reports Mortgages RESPA TILA

CFPB finalizes amendments to TILA/RESPA integrated disclosures rule and loan originator rule

On Tuesday, January 20, the CFPB promulgated its first final rule of 2015, a series of minor amendments to the TILA/RESPA integrated disclosures (TRID) rule. The substantive changes to the TRID rule are (1) an extension of...more

1/23/2015 - CFPB Final Rules Integrated Disclosures Mortgage Lenders Mortgage Loan Originators Mortgages RESPA TILA Time Extensions

CFPB report explores consumers’ mortgage shopping experience

In a report released on January 13, 2015, the CFPB announced that nearly half of consumers do not shop among multiple lenders before applying for a mortgage loan. Even fewer—about one of every four—submit multiple...more

1/16/2015 - CFPB FHFA Information Reports Mortgage Lenders Mortgages

CFPB increases appraisal requirement exemption threshold

The CFPB, Fed, and OCC have adjusted the threshold for smaller loans that are exempt from the appraisal requirement for “higher priced mortgage loans.” The appraisal requirement became effective January 18, 2014, and the...more

12/24/2014 - Appraisal CFPB Federal Reserve Loans Mortgage Lenders Mortgages OCC Secured Lenders

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