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Volume 18 - Number 2

January 24, 2014

CFPB Disclosure Rule Escalates Legal Liability

One sign of just how seriously Congress took the issue of consumer disclosure in the aftermath of the mortgage market meltdown is the dramatic escalation lenders will face for violating the new integrated disclosures from the Consumer Financial Protection Bureau, which take effect Aug. 1, 2015. Consider this: Under the Truth in Lending Act, lenders face a private right of action for violations (along with attorney’s fees and costs), as well as statutory penalties of up to $4,000 for failures to ...

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With originations expected to drop in 2018, will your shop turn to non-QM/non-prime mortgage products as a way to bolster volumes?

Yes, definitely. We’re planning a launch.


No. It’s still difficult compliance/regulatory-wise.


Maybe. It’s under consideration.


Not now. But things could change as 2018 progresses.