CFPB Releases Second Update Of Examination Procedures For Mortgage Rules


On August 15, the CFPB released new TILA and RESPA examination procedures, updated to cover all mortgage origination rules issued through May 29, 2013 and all mortgage servicing rules issued through July 10, 2013. The CFPB intends the updated procedures to help prepare financial institutions and mortgage companies for examinations regarding the new mortgage rules covering ability-to-repay requirements, qualified mortgages, high-cost mortgages, servicing, appraisals for higher-priced mortgage loans, and loan originator compensation.  Please see our summaries of the key rules here and here.

Notably, the new examination procedures do not reflect the amendments proposed by the CFPB in June, which are expected to be finalized shortly.  It is unclear whether the CFPB intends to update the procedures to reflect these and any other amendments.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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