Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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CFPB publishes TRID rule questions index

The CFPB has posted on its website an index to the various questions regarding the TILA/RESPA Integrated Disclosure (TRID) rule that were addressed during the five webinars on the rule conducted by CFPB staff. The index...more

8/18/2015 - CFPB Consumer Lenders Creditors Financial Institutions Financial Services Industry Loans Mortgage Lenders Mortgages TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB eClosing Project Update

The CFPB issued a report on its study of the CFPB’s mortgage loan eClosing project on August 5, 2015, and held a public forum addressing the study results. As we reported, the CFPB launched the eClosing project to determine...more

8/7/2015 - Banking Sector Banks CFPB Closing Documents Compliance Consumer Lenders Filing Requirements Financial Institutions Financial Services Industry Lenders Mortgage Lenders Mortgage Servicers Mortgages TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB eClosing project update

On August 5, 2015, the CFPB issued a report on its study of the CFPB’s mortgage loan eClosing project and held a public forum addressing the study results. As we reported, the CFPB launched the eClosing project to determine...more

8/7/2015 - Banking Sector Banks Borrowers CFPB Closing Documents Consumer Lenders Disclosure Requirements Electronic Filing Financial Institutions Financial Services Industry Mortgage Lenders Mortgages Real Estate Market Real Estate Transactions TILA-RESPA Integrated Disclosure Rule (TRID)

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

7/13/2015 - Ability-to-Repay CFPB FDIC OCC Qualified Mortgage Rule RESPA TILA TILA-RESPA Integrated Disclosure Rule (TRID)

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)

Divided U.S. Supreme Court Holds Disparate Impact Claims Cognizable Under FHA, but Subject to Safeguards Against Abusive Disparate...

A sharply divided U.S. Supreme Court announced its decision in Texas Department of Housing and Community Affairs v. The Inclusive Communities Project, Inc., on June 25, 2015, holding that disparate impact claims are...more

7/1/2015 - Affordable Housing Disparate Impact Fair Housing Act FHA SCOTUS Texas Dept of Housing v Inclusive Communities

Federal Agencies Finalize Flood Insurance Rules

Federal regulators have finalized a joint rule that amends regulations relating to loans secured by properties in special flood hazard areas. The final rule implements changes to the Flood Disaster Protection Act of 1973...more

6/30/2015 - Biggert-Waters Flood Insurance Reform Act Flood Disaster Protection Act Flood Insurance Flood Zones

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)

Final Diversity and Inclusion Standards Issued Jointly by Six Federal Agencies

Pursuant to a mandate contained in Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank or Act), six federal agencies jointly issued new Diversity and Inclusion (D&I) Standards today. These...more

6/11/2015 - Diversity Diversity and Inclusion Standards (D&I) Dodd-Frank Employer Mandates Hiring & Firing OMWI Regulatory Standards

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 and DOJ announce settlement with mortgage lender charged with discriminatory broker compensation policy

The CFPB announced last week that, together with the Department of Justice (DOJ), it had entered into a proposed consent order with Provident Funding Associates, a wholesale mortgage lender, to settle charges that Provident...more

6/2/2015

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 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

House passes bill to amend TILA points and fees definition for mortgage loans

Earlier this week, the House of Representatives passed a bill to amend the TILA definition of “points and fees” that is used to determine whether a loan is a high-cost mortgage or, for purposes of TILA’s ability to repay...more

4/20/2015 - Mortgage Escrow Account Mortgage Lenders Mortgages New Legislation TILA Title Insurance

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