Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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CFPB Publishes New Annotated Loan Disclosures

In emails sent to CFPB email subscription holders, the CFPB announced the publication of new annotated versions of the Loan Estimate and Closing Disclosure that include citations to sections in Chapter 2 of the Truth in...more

5/31/2016 - Banking Sector CFPB Consumer Financial Products Consumer Lenders Mortgage Lenders Mortgages Regulation Z TILA-RESPA Integrated Disclosure Rule (TRID) Truth in Lending Act (TILA)

CFPB Publishes New Annotated Loan Disclosures

In emails sent to CFPB email subscription holders, the CFPB announced the publication of new annotated versions of the Loan Estimate and Closing Disclosure that include citations to sections in Chapter 2 of the Truth in...more

5/16/2016 - CFPB Closing Documents Disclosure Requirements Dodd-Frank Mortgages TILA-RESPA Integrated Disclosure Rule (TRID) Truth in Lending Act (TILA)

CFPB publishes two resources for small creditors

The CFPB recently published a fact sheet for small creditors operating in rural or underserved areas. As we have reported, the CFPB issued a final rule, which became effective on January 1, 2016, revising the definitions of...more

5/4/2016 - Banking Sector CFPB Qualified Mortgage Rule Regulation Z Rural Areas Small Credit Institutions Truth in Lending Act (TILA)

Industry Trade Groups Renew Challenge to HUD Disparate Impact Rule

Two industry trade associations whose members sell homeowners insurance have been granted leave to file an amended complaint in their lawsuit challenging the Fair Housing Act (FHA) disparate impact rule (Rule) adopted by the...more

4/22/2016 - Administrative Procedure Act Affordable Housing Disparate Impact Fair Housing Act (FHA) Homeowner's Insurance Motion to Amend Race Discrimination SCOTUS Texas Dept of Housing v Inclusive Communities

CFPB Issues Second Rule to Implement the HELP Act, Expanding Qualified Mortgage Coverage for Lenders in Rural and Underserved...

As we have addressed, Congress passed the Helping Expand Lending Practices in Rural Communities Act of 2015 (HELP Act) on December 4, 2015, in efforts to expand the designation of additional areas as being "rural" under...more

4/15/2016 - Ability-to-Repay CFPB Comment Period Escrow Accounts Final Rules HELP Act Mortgages New Legislation Regulation Z Rural Areas Truth in Lending Act (TILA)

CFPB issues second rule to implement the HELP Act, expanding Qualified Mortgage coverage for lenders lending in rural and...

As we have addressed, Congress passed the Helping Expand Lending Practices in Rural Communities Act of 2015 (HELP Act) on December 4, 2015, in efforts to expand the designation of additional areas as being “rural” under...more

3/31/2016 - Ability-to-Repay CFPB Mortgages Qualified Mortgage Rule Regulation Z Residential Real Estate Market Rural Areas Rural Development Truth in Lending Act (TILA)

CFPB Staff Presents TRID Rule Webinar

The Consumer Financial Protection Bureau (CFPB) staff presented an informational webinar on March 1, 2016, to address several issues with the TILA/RESPA Integrated Disclosure (TRID) rule in connection with...more

3/22/2016 - CFPB Construction Industry Construction Loans Mortgages Residential Real Estate Market TILA-RESPA Integrated Disclosure Rule (TRID)

Survey Says: TRID Extends Processing Times and Limits Products Offered

The American Bankers Association (ABA) has released findings from its recent 2016 ABA TRID Survey focusing on the TILA/RESPA Integrated Disclosure (TRID) rule’s effect on the residential mortgage lending market. The findings,...more

3/7/2016 - American Bankers Association Banking Sector Mortgage Lenders Mortgages Surveys TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB invites comments on “Application Process for Designation of Rural Area under Federal Consumer Financial Law”

As we previously addressed, the CFPB issued a final rule to expand the definition of “rural areas” under Regulation Z with regard to the authority of small creditors to make certain qualified mortgage loans under the ability...more

2/24/2016 - CFPB Comment Period Escrow Accounts Final Rules HELP Mortgage Lenders Regulation Z Rural Development

TRID Rule Technical Correction?

In the Federal Register the Consumer Financial Protection Bureau (CFPB) published a correction to the TILA/RESPA Integrated Disclosure (TRID) rule supplementary information as published on December 31, 2013, with regard to...more

2/22/2016 - CFPB Escrow Accounts HOA Dues Mortgages Property Tax TILA-RESPA Integrated Disclosure Rule (TRID)

Federal Reserve Repeals Regulation AA, Proposes Repeal of Regulation C

The Federal Reserve Board (Board) is repealing Regulation AA, which includes the Board's credit practices rule, effective March 21, 2016. The Board is also proposing to repeal its Regulation C, which historically implemented...more

2/19/2016 - Banks CFPB Comment Period Dodd-Frank Federal Reserve FTC Act HMDA Mortgages Regulation AA Regulation C

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)

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