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Mortgages Truth in Lending Act (TILA) Regulation Z

The term "mortgage" typically refers to a mortgage loan.  A mortgage loan is a financing instrument where an individual or business borrows money to purchase property (usually real property) and... more +
The term "mortgage" typically refers to a mortgage loan.  A mortgage loan is a financing instrument where an individual or business borrows money to purchase property (usually real property) and uses that property as collateral for the loan. less -
Cadwalader, Wickersham & Taft LLP

CFPB Addresses “Contracts for Deeds,” a Mortgage-Like Product That Has Recently Gained Popularity

On August 13th, the Consumer Financial Protection Bureau (“CFPB”) published a consumer advisory as well as an advisory opinion addressing “contracts for deeds”, which are also variously called a “bond for deed”, “land...more

Cooley LLP

CFPB Deems Contracts for Deed ‘Credit’ Subject to Regulation Z

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On August 13, 2024, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion stating that contracts for deed are “credit” under Regulation Z, and therefore subject to its myriad requirements. Unlike a...more

Sheppard Mullin Richter & Hampton LLP

CFPB Announces Advisory Opinion on Applicability of TILA and Regulation Z To Contracts for Deed

On August 13, the CFPB announced an advisory opinion on the applicability of the Truth in Lending Act (TILA) and Regulation Z to “contracts for deed.” A contract for deed is an arrangement in which a consumer purchases a home...more

Troutman Pepper

CFPB Advises Against Certain Contract-for-Deed Practices

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This week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion and a research report addressing contract-for-deed home financing, also known as a “land contract,” “land installment contract,”...more

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2024

The federal banking agencies have published joint guidance for banks about risks posed by fintech companies and other third parties to deliver bank deposit products and services. The joint guidance issued on July 30...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - July 2024 # 4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Ballard Spahr LLP

HUD, Fannie Mae and Freddie Mac Issue Reconsideration of Value Guidance to Combat Appraisal Bias

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The U.S. Department of Housing and Urban Development (HUD), through the Federal Housing Administration (FHA), recently issued Mortgagee Letter 2024-07 addressing reconsideration of value (ROV) policies in connection with...more

Cadwalader, Wickersham & Taft LLP

Consumer Credit and Leasing Thresholds Updated for 2023

For purposes of general applicability of the Truth in Lending Act and Regulation Z to credit transactions and the Consumer Leasing Act and Regulation M for lease transactions, the Consumer Financial Protection Bureau ("CFPB")...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Troutman Pepper

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

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On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are...more

Goodwin

Tougher Standards for Certain Home Improvement Loans

Goodwin on

On May 1, 2023, the Consumer Financial Protection Bureau (CFPB) issued a report and a proposed rule to clarify and strengthen its regulation of so-called Property Assessed Clean Energy (PACE) financing. PACE financing is...more

Orrick, Herrington & Sutcliffe LLP

CFPB shutters mortgage lender, alleging deceptive advertising

On February 27, the CFPB entered a consent order against a California-based mortgage lender (respondent) for alleged repeat violations of the Consumer Financial Protection Act, TILA (Regulation Z), and the Mortgage Acts and...more

Nutter McClennen & Fish LLP

Nutter Bank Report: February 2023

Federal Guidance Warns of Liquidity Risks Arising from Crypto-Asset-Related Deposits - The federal banking agencies have issued joint guidance to banking organizations highlighting potentially heightened liquidity risks...more

Orrick, Herrington & Sutcliffe LLP

CFPB adjusts annual dollar amount thresholds under TILA, HMDA regulations

On December 21, the CFPB released a final rule revising the dollar amounts for provisions implementing TILA and its amendments that impact loans under the Home Ownership and Equity Protection Act of 1994 (HOEPA) and qualified...more

Troutman Pepper

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

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On October 13, the Consumer Financial Protection Bureau, the Federal Reserve Board, and the Office of the Comptroller of the Currency announced increased dollar thresholds used to determine whether certain consumer credit and...more

Ballard Spahr LLP

Divided Eleventh Circuit panel rules TILA-required monthly mortgage statements can constitute debt collection communications...

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A divided panel of the U.S. Court of Appeals for the Eleventh Circuit in Daniels v. Select Portfolio Servicing, Inc. held last week that monthly mortgage statements required under the Truth in Lending Act and Regulation Z can...more

Holland & Knight LLP

CFPB Issues Final Libor Transition Rules

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The Consumer Financial Protection Bureau (the Bureau) has issued final regulations (Final Regulations) to facilitate the transition away from Libor (the London Interbank Offered Rate) in the consumer credit market and to...more

Wiley Rein LLP

Wiley Consumer Protection Download (December 13, 2021)

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Thank you for your interest in the Wiley Consumer Protection Download! This will be our last publication of 2021, with our bi-weekly newsletter returning in January 2022. Welcome to Wiley’s update on recent developments...more

Troutman Pepper

Updates to TILA Interagency Guidance and Certain Annual Thresholds

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Two important updates impacting compliance with the Truth in Lending Act (TILA) and Reg Z have just been announced....more

Ballard Spahr LLP

CFPB issues statement on Juneteenth bill Truth in Lending Act issue

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As previously reported, the bill signed into law by President Biden on June 17, 2021 to create the Juneteenth National Independence Day actually results in an important change under the Truth in Lending Act (TILA) and...more

Ballard Spahr LLP

CFPB Enters Into Consent Order With Reverser Mortgage Lender and Broker

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The CFPB recently entered into a consent order with Nationwide Equities Corporation (Nationwide), which the CFPB refers to as a mortgage broker and mortgage lender that primarily provides jumbo reverse mortgage loans and Home...more

Goodwin

CFPB Sues Connecticut-Based Mortgage Lender

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On January 15, 2021, the Consumer Financial Protection Bureau (CFPB) announced it had filed suit in the United States District Court for the District of Connecticut against a Connecticut-based mortgage company and three...more

Ballard Spahr LLP

CFPB Adjusts HMDA and TILA Asset Exemption Thresholds

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The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA)...more

Perkins Coie

The CFPB Proposes Amendments to the Qualified Mortgage Definition in Regulation Z and Extends the GSE Patch

Perkins Coie on

The Consumer Financial Protection Bureau (CFPB) recently proposed certain amendments to the General Qualified Mortgage (QM) definition in Regulation Z and issued a filing rule extending the expiration of the...more

Goodwin

CFPB Proposes New “Seasoned” Qualified Mortgage Category

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On August 18, 2020, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule to create a new category of loans known as “seasoned” qualified mortgages (Seasoned QMs). This new category of qualified mortgages...more

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