Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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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 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

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)

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 Loans Mortgage Lenders Mortgages TILA-RESPA Integrated Disclosure Rule (TRID)

House Financial Services Committee passes CFPB-related bills including bill creating TRID Rule hold harmless period

On July 29, the following four CFPB-related bills were passed by the House Financial Services Committee: H.R. 3192, the “Homebuyers Assistance Act”: The bill would provide a hold harmless period for the TILA/RESPA Integrated...more

8/10/2015 - Anti-Steering Rules Banking Sector Banks CFPB Consumer Lenders DOJ Financial Institutions First Time Homebuyers FTC Lenders Minority-Owned Businesses Mortgage Lenders Mortgages Real Estate Market Small Business TILA-RESPA Integrated Disclosure Rule (TRID) Women-Owned Businesses

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 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 Mortgage Lenders Mortgages Real Estate Market Real Estate Transactions TILA-RESPA Integrated Disclosure Rule (TRID)

House Financial Services Committee passes CFPB-related bills including bill creating TRID Rule hold harmless period

Wednesday, the following four CFPB-related bills were passed by the House Financial Services Committee: H.R. 3192, the “Homebuyers Assistance Act”: The bill would provide a hold harmless period for the TILA/RESPA Integrated...more

7/31/2015 - Anti-Steering Rules Automotive Industry Automotive Loans Banking Sector Banks CFPB DOJ Financial Institutions Financing First Time Homebuyers Mortgage Loan Originators Mortgages Qualified Mortgage Rule Residential Real Estate Market TILA-RESPA Integrated Disclosure Rule (TRID)

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-RESPA Integrated Disclosure Rule (TRID) Truth in Lending Act (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 Truth in Lending Act (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 Title Insurance Truth in Lending Act (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

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