Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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TRID rule technical correction?

In yesterday's Federal Register the CFPB published a correction to the TILA/RESPA Integrated Disclosure (TRID) rule supplementary information as published on December 31, 2013 with regard to property taxes and certain similar...more

2/11/2016 - CFPB Property Tax TILA-RESPA Integrated Disclosure Rule (TRID)

DOJ Settles Action Alleging Bank Discriminated Against Disability Income Recipients

The U.S. Department of Justice recently entered into a consent order with Evolve Bank & Trust to settle charges that the bank discriminated against mortgage loan applicants on the basis of disability and receipt of public...more

2/3/2016 - Banking Sector Consent Order Disability Discrimination DOJ ECOA Fair Housing Act (FHA) Mortgage Lenders Qualified Settlement Funds

CFPB Construction Loan "Fact Sheet" Falls Far Short of Necessary Guidance

The Consumer Financial Protection Bureau (CFPB) has issued a "fact sheet" regarding the disclosure of construction-to-permanent loans under the TILA/RESPA Integrated Disclosure (TRID) rule, which the CFPB refers to as the...more

1/25/2016 - CFPB Construction Industry Construction Loans Popular Regulation Z TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB construction loan “fact sheet” falls far short of necessary guidance

The CFPB has issued what it calls a “fact sheet” regarding the disclosure of construction-to-permanent loans under the TILA/RESPA Integrated Disclosure (TRID) rule, which the CFPB refers to as the Know Before You Owe rule....more

1/16/2016 - CFPB Construction Loans Disclosure Requirements Mortgages TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB seeks input on HMDA resubmissions

The CFPB has issued a request for information (RFI) seeking information on what changes to the CFPB’s HMDA Resubmissions Guidelines may be appropriate. The RFI responds to comments received by the CFPB in connection with its...more

1/11/2016 - Banking Sector CFPB HMDA Mortgages Request For Information

CFPB responds to industry concerns about TRID rule liability

Reacting to reports of investors refusing to purchase loans based on various, often technical, violations of the TILA/RESPA Integrated Disclosure (TRID) rule, the Mortgage Bankers Association (MBA) sent a letter to the CFPB...more

12/31/2015 - CFPB Investors Mortgage Bankers Association Mortgages TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB issues TRID rule corrections

The CFPB has issued a final rule containing “technical corrections” to the final TILA-RESPA Integrated Disclosure (TRID) rule that became effective on October 3, 2015. The corrections are effective December 24, 2015, the date...more

12/29/2015 - CFPB Final Rules Mortgages Regulation Z TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB issues TRID rule corrections

The CFPB has issued a final rule containing “technical corrections” to the final TILA-RESPA Integrated Disclosure (TRID) rule that became effective on October 3, 2015. The corrections are effective December 24, 2015, the date...more

12/29/2015 - CFPB Final Rules Mortgages Regulation Z TILA-RESPA Integrated Disclosure Rule (TRID)

New Loan Limits for 2016 Announced by FHA

The Federal Housing Administration (FHA) announced the 2016 Nationwide Forward Mortgage Limits in Mortgagee Letter 2015-30 and the 2016 Nationwide Home Equity Conversion Mortgage (HECM) limits in Mortgagee Letter 2015-29...more

12/21/2015 - Federal Housing Administration (FHA) Freddie Mac HECM HUD Mortgages

CFPB Outlines Exam Priorities for 2016

The Consumer Financial Protection Bureau's (CFPB) deputy assistant director for origination recently warned mortgage lenders of the four main examination priorities for 2016—loan originator compensation plans, the...more

12/18/2015 - Ability-to-Repay CFPB Industry Examinations Marketing Services Agreements Mortgage Lenders TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB outlines exam priorities for 2016

The CFPB’s Deputy Assistant Director for origination recently warned mortgage lenders of the four main examination priorities for 2016—loan originator compensation plans, the ability-to-repay rule, the TILA-RESPA Integrated...more

12/18/2015 - CFPB Industry Examinations Marketing Services Agreements Mortgage Lenders TILA-RESPA Integrated Disclosure Rule (TRID)

Reduced HOEPA/QM points and fees limits; revisions to Reg Z small creditor/rural area definitions and asset test effective January...

Since it is unusual for CFPB annual adjustments to result in reduced thresholds, we want to remind blog readers of the reduced HOEPA and QM points and fee limits that will be effective January 1, 2016. Effective January 1,...more

12/10/2015 - CFPB HOEPA Mortgage Lenders Qualified Mortgage Rule Regulation Z Threshold Requirements

CFPB releases HMDA Rule Compliance Guide

The CFPB released the Home Mortgage Disclosure (Regulation C) Small Entity Compliance Guide  on December 1, 2015. According to the CFPB, the purpose of the Compliance Guide is to provide an accessible summary of Regulation C,...more

12/7/2015 - CFPB HMDA Mortgages Regulation C Small Entity Compliance Guide

House Passes Bill to Curb QM requirements

The U.S. House of Representatives passed a bill that would provide a safe harbor exception for depository institutions from certain provisions of the Truth in Lending Act and Regulation Z, and for mortgage originators from...more

12/7/2015 - Anti-Steering Rules Depository Institutions Mortgage Loan Originators Qualified Mortgage Rule Regulation Z Safe Harbors Truth in Lending Act (TILA)

DOJ Settles Fair Lending Claims Based on Bank’s Mortgage Pricing System

The U.S. Department of Justice (DOJ) has announced a proposed consent order with Sage Bank to settle charges that the bank violated the Fair Housing Act (FHA) and the Equal Credit Opportunity Act (ECOA) by discriminating on...more

12/7/2015 - Consent Order DOJ ECOA Fair Housing Act (FHA) Mortgage Lenders Race Discrimination

Final HMDA rule makes significant changes

As we previously reported, the CFPB has issued a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act. The final rule makes many significant changes, including changes to the rule’s coverage and...more

11/10/2015 - CFPB Final Rules HMDA

Final HMDA rule makes significant changes

As we previously reported, the CFPB has issued a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act. The final rule makes many significant changes, including changes to the rule’s coverage and...more

10/23/2015 - Banking Sector Banks CFPB Final Rules Financial Institutions HMDA Mortgage Lenders Mortgage Servicers Mortgages Regulation C

Transitional period and initial supervisory practice over TRID

The CFPB sent industry trade groups a letter on October 1, 2015 to address the approach of the Federal Financial Institutions Examination Council (FFIEC) member agencies during the initial months following the implementation...more

10/23/2015 - Banking Sector Banks CFPB Compliance Consumer Lenders Fannie Mae FFIEC Financial Institutions First Time Homebuyers Freddie Mac Good Faith GSE Guidance Update Industry Examinations Lenders Mortgage Lenders Mortgages TILA-RESPA Integrated Disclosure Rule (TRID)

Summary of Final Rule Amending HMDA and What It Means for Covered Institutions

The Consumer Financial Protection Bureau (CFPB) has released a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA), requiring most lenders to report certain information about mortgage...more

10/22/2015 - Banking Sector Banks CFPB Compliance Consumer Lenders Covered Entities Financial Institutions HMDA Homeowners Mortgage Lenders Mortgage Servicers Mortgages Regulation C Underwriting

Director Cordray sends warning to vendors on TRID rule compliance

In remarks yesterday at the Mortgage Bankers Association’s annual convention, CFPB Director Richard Cordray stated that the CFPB may need to look more closely at vendors of software and other tools used by lenders to comply...more

10/21/2015 - Banking Sector Banks CFPB Closing Documents Compliance Consumer Lenders Disclosure Requirements Financial Institutions Financial Regulatory Reform Homeowners Mortgage Bankers Association Mortgage Lenders Mortgage Servicers Mortgages Residential Real Estate Market Software TILA-RESPA Integrated Disclosure Rule (TRID) Vendors

CFPB issues final HMDA rule

The CFPB has issued a final rule amending Regulation C, its Home Mortgage Disclosure Act regulation. The changes, which, in part, implement the Dodd-Frank Act’s amendments to HMDA, expand the scope of data required to be...more

10/20/2015 - CFPB Compliance Data Collection Depository Institutions Disclosure Requirements Dodd-Frank Financial Institutions Financial Transactions HMDA Mortgage Lenders Mortgages Regulation C Reporting Requirements Threshold Requirements

Transitional period and initial supervisory practice over TRID

The CFPB sent industry trade groups a letter on October 1, 2015 to address the approach of the FFIEC member agencies during the initial months following the implementation of the TILA-RESPA Integrated Disclosure (TRID) rule...more

10/13/2015 - Banking Sector Banks CFPB Compliance Fannie Mae FFIEC Financial Institutions Freddie Mac GSE Home Buyer Homeowners Industry Examinations Mortgage Lenders Mortgage Servicers Mortgages Residential Real Estate Market TILA-RESPA Integrated Disclosure Rule (TRID)

House Passes Bill to Delay TRID

On October 7, 2015, the U.S. House of Representatives passed a bill that would provide a safe harbor from the new TILA/RESPA Integrated Disclosure (TRID) rule for a period of five months. By a vote of 303 to 121 the House...more

10/12/2015 - Banking Sector CFPB Compliance Consumer Lenders Financial Institutions Good Faith Hold Harmless Home Buyer Mortgage Lenders Mortgages Safe Harbors TILA-RESPA Integrated Disclosure Rule (TRID) U.S. House

Be Careful What You Ask For, You May Get It—The CFPB Addresses Marketing Services Agreements Under RESPA

The residential mortgage settlement service industry has been asking the CFPB for guidance on the legality of marketing service agreements (MSAs) under RESPA. When questioned on the issue last week at a House Financial...more

10/9/2015 - Banking Sector CFPB Consumer Service Agreements Financial Institutions Financial Services Committee Kickbacks Mortgage Lenders Mortgage Servicers Mortgages National Mortgage Settlement Referral Fees RESPA Whistleblowers

CFPB issues final rule expanding definition of “small creditor” and “rural areas” under TILA

The CFPB has issued a final rule that revises the definitions of “small creditor” and “rural areas” under Regulation Z of the Truth in Lending Act (TILA). The final rule is effective January 1, 2016. We previously reported on...more

9/25/2015 - Ability-to-Repay Banking Sector CFPB Consumer Financial Products Consumer Lenders Creditors Final Rules Financial Institutions Loans Mortgage Lenders Mortgage Servicers Mortgages Regulation Z Truth in Lending Act (TILA)

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