Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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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)

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 “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)

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)

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 Counselor 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 Points and Fees TILA Title Insurance

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

4/17/2015 - Ability-to-Repay Amended Legislation Mortgage Lenders Qualified Mortgage Rule TILA

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

4/16/2015 - CFPB Final Rules Financial Education Initiatives 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

4/10/2015 - Advertising CFPA CFPB Consent Order Enforcement Actions Mortgage Lenders Regulation N TILA Unfair or Deceptive Trade Practices

CFPB updates home buying information booklet

The CFPB has issued an updated version of the home buying information booklet (also known as the special information or settlement cost booklet) required under RESPA and TILA. The new booklet is entitled “Your home loan...more

4/2/2015 - CFPB Home Buyer Mortgages RESPA TILA

Trade groups seek grace period for TILA/RESPA integrated disclosure rule

A group of 17 trade associations and organizations have written to the CFPB seeking a grace period for enforcement of the TILA-RESPA Integrated Disclosure (TRID) rule which becomes effective on August 1, 2015. In their...more

3/23/2015 - CFPB Grace Period Integrated Disclosures RESPA TILA Trade Associations

CFPB Report Explores Consumers’ Mortgage Shopping Experience

In a report released on January 13, 2015, the Consumer Financial Protection Bureau announced that nearly half of consumers do not shop among multiple lenders before applying for a mortgage loan. Even fewer—about one of every...more

1/26/2015 - CFPB Consumer Financial Products FHFA Information Reports Mortgages RESPA TILA

CFPB finalizes amendments to TILA/RESPA integrated disclosures rule and loan originator rule

On Tuesday, January 20, the CFPB promulgated its first final rule of 2015, a series of minor amendments to the TILA/RESPA integrated disclosures (TRID) rule. The substantive changes to the TRID rule are (1) an extension of...more

1/23/2015 - CFPB Final Rules Integrated Disclosures Mortgage Lenders Mortgage Loan Originators Mortgages RESPA TILA Time Extensions

CFPB QM cure and other mortgage rule amendments now effective; HUD nixes CFPB cure for FHA QM rule

The CFPB’s final rule amending certain provisions of the 2013 Title XIV final mortgage rules which includes a post-consummation points and fees cure mechanism for qualified mortgage loans, became effective on Monday, November...more

11/6/2014 - CFPB FHA Final Rules HUD Qualified Mortgage Rule Regulation X RESPA TILA

CFPB finalizes amendments to mortgage rules

The CFPB has issued a final rule amending certain provisions of the 2013 Title XIV final mortgage rules. While in its press release the CFPB describes the amendments as “minor adjustments to its mortgage rules,” the final...more

10/24/2014 - CFPB Mortgage Servicing Rules Mortgages RESPA TILA Title XIV

CFPB Answers FAQ on the TILA-RESPA Integrated Disclosures Rule

On August 26, 2014, the CFPB staff and Federal Reserve Board co-hosted a webinar and addressed questions about the final TILA-RESPA Integrated Disclosures Rule that will be effective for applications received by creditors or...more

8/29/2014 - CFPB Creditors Disclosure Requirements Final Rules Mortgage Brokers RESPA TILA

CFPB Provides Guidance on Ability-To-Repay Rule Application to Assumptions of Residential Mortgage Loans

The CFPB recently provided guidance on the application of the Regulation Z ability-to-repay rule (Section 1026.43) to assumptions of residential mortgage loans for purposes of clarifying the application of the rule in cases...more

7/17/2014 - Ability-to-Repay Beneficiaries CFPB Mortgages Popular Regulation Z TILA

CFPB issues policy guidance on mini-correspondent structure for mortgage lenders

On July 11, 2014, the CFPB issued supervisory and enforcement guidance entitled “Policy Guidance on Supervisory and Enforcement Considerations Relevant to Mortgage Brokers Transitioning to Mini-Correspondent Lenders.” The...more

7/15/2014 - CFPB Lenders Mortgages RESPA TILA

House passes bill to modify TILA “points and fees” definition

H.R. 3211, which amends the Truth in Lending Act’s definition of “points and fees,” was passed by a voice vote in the House of Representatives on June 9, 2014. The “points and fees” definition is used to determine...more

6/13/2014 - Mortgages RESPA TILA

CFPB issues small entity compliance guide for RESPA/TILA integrated disclosure rule

The CFPB recently issued an 89-page small entity compliance guide for the TILA-RESPA Integrated Disclosure Rule (the “Guide”). As we reported previously, the CFPB issued the final rule in November 2013 to integrate the...more

4/3/2014 - CFPB Mortgage Loan Servicing Standards Mortgages RESPA TILA

CFPB Releases Final RESPA-TILA Integrated Disclosures Rule

On November 20, the Consumer Financial Protection Bureau released the nearly 1,900-page final RESPA-TILA Integrated Disclosures Rule. The rule will be effective for applications received on or after August 1, 2015. The...more

11/26/2013 - CFPB Mortgages RESPA TILA

CFPB issues final consolidated mortgage disclosure rule

Today, the CFPB issued its long-awaited final rule consolidating the application and closing disclosures required by the Real Estate Settlement Procedures Act and Truth in Lending Act for mortgage loan transactions....more

11/20/2013 - CFPB Mortgages RESPA TILA

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