Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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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

TILA Ban on Mandatory Arbitration in Mortgage Loans Takes Effect June 1

The Truth in Lending Act (TILA) ban on mandatory arbitration provisions in certain mortgage loans becomes effective on June 1, 2013. Lenders now using mortgage loan documentation containing such provisions should take steps...more

5/17/2013 - Dodd-Frank Mandatory Arbitration Clauses Mortgages Regulation Z TILA

Borrower Can Sue After Three Years to Rescind Mortgage Loan, 3rd Circuit Rules

A borrower can bring a lawsuit seeking rescission more than three years after loan consummation as long as the borrower has sent a written notice of rescission within the three-year period, the U.S. Court of Appeals for the...more

2/7/2013 - Borrowers Loans Mortgages Rescission Statute of Limitations TILA Written Notice

CFPB issues final rules on mortgage servicing, appraisals and loan originator compensation

The regulatory barrage continued last week with the CFPB issuing the last batch of mortgage-related rules it was required to finalize by the Dodd-Frank Act’s January 21 deadline....more

1/23/2013 - CFPB Compensation & Benefits Dodd-Frank Higher-Priced Mortgage Loans Mortgage Loan Originators Mortgages Regulation Z TILA

Agencies Adopt Final Appraisal Rule for Higher-Priced Mortgage Loans

Today, the federal financial institution agencies (the FDIC, Fed, OCC, and NCUA), the CFPB, and the Federal Housing Finance Agency adopted a joint final rule to implement Dodd-Frank appraisal requirements for higher-priced...more

1/21/2013 - CFPB Dodd-Frank FDIC Federal Reserve Higher-Priced Mortgage Loans Mortgages NCUA OCC TILA

CFPB Issues Final Mortgage Escrow Account and High-Cost Loan Rules

Last week was a busy one for the CFPB. In addition to the final ability to repay/qualified mortgage rule, the CFPB also issued final rules on mortgage escrow accounts and high-cost home loans....more

1/15/2013 - CFPB Dodd-Frank HOEPA Mortgage Escrow Account Mortgages TILA

High-Cost Loan Final Rule Temporarily Averts FHA Loan Crisis

On January 10, 2013, the CFPB issued a final high-cost loan rule under Dodd-Frank that includes a modified version of a proposal that will temporarily avoid a crisis with FHA loans....more

1/14/2013 - CFPB Dodd-Frank FHA HOEPA Mortgages TILA

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