Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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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)

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

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)

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