Residential Real Estate Consumer Protection

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Coming Soon... New Closing (no, Consummation...) Rules!

What?! We can’t call it a closing anymore? Under new federal regulations regarding the Truth in Lending Act (“TILA”) and the Real Estate Settlement Procedures Act (“RESPA”), the terminology for a “closing” or “settlement” is...more

Los Angeles Proposing Strict Regulations on Short-term Vacation Rentals, But to What Effect?

In recent years, the short-term online vacation rental market has flourished, and connecting travelers with short-term bedroom, apartment, or home rentals has become what many value as a billion dollar industry. The industry...more

CFPB Officially Moves TRID Effective Date To October 3

The CFPB has issued a final rule postponing the effective date for all provisions of the TILA-RESPA Final Rule and Amendments to October 3, 2015. The final rule also includes certain technical amendments to reflect the new...more

CFPB Finalizes TRID’s Final Effective Date

On Tuesday, July 21, 2015, the Consumer Financial Protection Bureau (CFPB) finalized a rule that delays the effective date of the Truth in Lending Act and Real Estate Settlement Procedures Act rules integrating certain...more

Consumer Financial Protection Bureau: The Consumer Financial Protection Bureau's new "Know Before You Owe" Mortgage Disclosure...

The Consumer Financial Protection Bureau (“CFPB”) recently issued or perhaps had to issue a proposed amendment to the “Know Before You Owe mortgage disclosure rule,” also known as the “TILA-RESPA Integrated Disclosure” rule,...more

CFPB Moves TRID Effective Date to October 3

In previous blog postings, we discussed an informal announcement from the Consumer Financial Protection Bureau (CFPB) of its intent to delay the effective date of the new integrated mortgage disclosure rule under Truth In...more

CFPB officially moves TRID effective date to October 3

The CFPB has issued a final rule postponing the effective date for all provisions of the TILA-RESPA Final Rule and Amendments to October 3, 2015. The final rule also includes certain technical amendments to reflect the new...more

CFPB Monthly Reports to Emphasize Consumer Complaint Trends

On July 16, 2015, the Consumer Financial Protection Bureau (CFPB) issued the first in a new series of monthly reports that will “highlight key trends from consumer complaints submitted to the [CFPB].” According to the CFPB...more

Special Alert: CFPB Officially Delays TRID Rule Until October 3

The CFPB finalized a rule today that delays the effective date of the TILA-RESPA Integrated Disclosure (“TRID”) rule, including all amendments, from August 1 to October 3, 2015. This is consistent with the proposed rule...more

How to Respond to a CFPB Civil Investigative Demand

The Consumer Financial Protection Bureau (“CFPB”) was created to enforce the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank”) and various consumer finance laws (e.g., Equal Credit Opportunity...more

Director Cordray appears before Senate Banking Committee

On Wednesday, July 15, CFPB Director Richard Cordray appeared before the Senate Committee on Banking, Housing, & Urban Affairs to answer questions regarding the Bureau’s Semi-Annual Report to Congress and the President, which...more

CFPB Postpones “Know Before You Owe” Mortgage Rule Until October 3

On June 24, the Consumer Financial Protection Bureau (CFPB) issued a proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3. The rule, also...more

OCC Identifies Safety and Soundness Risks to National Banks and Federal Savings Associations and Supervisory Priorities

A new report issued by the federal Office of the Comptroller of the Currency (OCC) identifies top safety and soundness risks to national banks and federal savings associations, as well as OCC supervisory priorities for the...more

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

CFPB Enforces RESPA in its First Appellate Decision of the Director

In the first appeal of an administrative enforcement proceeding before the Consumer Financial Protection Bureau (“Bureau”), the administrative law judge (ALJ) concluded that PHH Corporation, a mortgage lender, referred...more

Lenders Get TRID Reprieve Thanks to CFPB Admin Error

Why it matters - An “administrative error” on the part of the Consumer Financial Protection Bureau (CFPB) may have been the best news lenders received in a long time. On August 1, the new TRID (TILA-RESPA Integrated...more

CFPB Reports Continued Mortgage Servicing and Other Violations of Consumer Financial Law

In its Supervisory Highlights recently released, which cover the period from January to April 2015, the Consumer Financial Protection Bureau (“The Bureau”) reported its examination observations in consumer reporting, debt...more

CFPB Delays Implementation of New TRID Form

For the second time in recent weeks, the Consumer Financial Protection Bureau (CFPB) delayed the launch of the new integrated disclosures for residential mortgage loans under the Truth in Lending Act (TILA) and Real Estate...more

Beyond the Commercials: Understanding Reverse Mortgages

You have likely seen the commercials for reverse mortgages. While the advertisements urge viewers to “call now to secure you reverse mortgage today” and make them seem risk-free, obtaining a mortgage of this type is a serious...more

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

CFPB Report Addresses Need for a Compliance Management System

The CFPB's Supervisory Report Provides Important Insight into the CFPB's Supervision and Enforcement Priorities and Desired Business Practices. HIGHLIGHTS: - The Consumer Financial Protection Bureau (CFPB)...more

Supervisory Haiku-lights, Summer 2015

Break out the short shorts everybody: it’s summer! We know you could use a palate cleanser between the 50 Shades novels and Game of Thrones wikis you’re reading on the beach. Supervisory Haiku-lights to the rescue! The Summer...more

CFPB Publishes Eighth Edition of Supervisory Highlights

On June 23, the CFPB published its eighth edition of Supervisory Highlights, covering supervisory activities from January 2015 through April 2015. The latest edition identifies issues with dual-tracking at mortgage servicers...more

CFPB further delays TRID effective date

The CFPB has issued its formal proposal to delay the effective date of the TILA-RESPA Integrated Disclosures (TRID) rule until Saturday, October 3, 2015. The new effective date comes only a week after the CFPB announced it...more

CFPB Publishes Over 7,700 Consumer Complaint Narratives About Financial Companies

The CFPB has gone live with an enhanced customer complaint data base. It now includes over 7,700 consumer descriptions of alleged problems they are facing with financial companies concerning mortgages, bank accounts, credit...more

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