TILA

Browse articles from all of our Newsletters related to TILA.

August 14, 2017

Inside the CFPB Full Issue August 14, 2017 (PDF)

View Inside the CFPB Full Issue August 14, 2017 (PDF)

August 14, 2017

TRID Related Deadlines for Amendments, Comments Now Set

The CFPB’s so-called TRID 2.0 amendments, and the related proposal to deal with the “black hole” problem – the limited ability of a lender to reset tolerances with a closing disclosure – were published in the Aug. 11, 2017, Federal Register. That act establishes Oct. 10, 2017, as the effective date of the TRID 2.0 amendments, as well as the comment deadline for the black hole proposal. The amendments, which were finalized in July, essentially codify the CFPB’s informal guidance on various issues and make additional clarifications and technical amendments. They also create tolerances for the total of payments, adjust a partial exemption mainly affecting housing finance agencies and nonprofits, and extend coverage of the Truth in Lending Act/Real Estate Settlement Procedures ...

July 31, 2017

Inside the CFPB Full Issue July 31, 2017 (PDF)

View Inside the CFPB Full Issue July 31, 2017 (PDF)

July 31, 2017

Reform to CFPB Mortgage Rules Needed to Attract Capital: PIMCO

If lawmakers and regulators are interested in bringing capital back to the private mortgage market and facilitating borrower access to credit in a responsible manner, they must make much-needed reforms to a handful of key mortgage rules promulgated by the CFPB, according to bond giant Pacific Investment Management Co. One recommended revision is eliminating the expansion of assignee liability for investors under the CFPB’s ability-to-repay rule. “Currently under the Dodd-Frank Act, mortgage investors are liable for mistakes made by lenders in the mortgage origination process for certain mortgage loans that are not deemed qualified mortgages,” said PIMCO. “Since investors have no role or discretion in the mortgage origination process, we believe this is not only nonsensical, but also has the ...

July 27, 2017

Industry Officials Call for Revisions to CFPB’s Many Mortgage Regulations

While policymakers in Washington, DC, are paying renewed attention to housing-finance reform, some industry representatives took advantage of the opportunity provided by a related hearing on Capitol Hill to also urge changes be made to a number of the mortgage-related rules promulgated in recent years by the Consumer Financial Protection Bureau. Bond giant PIMCO issued a report that called for a handful of key revisions to the mortgage regulatory landscape before any reform of Fannie Mae and Freddie Mac is undertaken. “To bring capital back to the private mortgage market and ensure credit is extended...

July 21, 2017

PIMCO Says Tackle Changes to Non-Agency Market, Then Do GSE Reform; Firm Critical of Plans Thus Far

Pacific Investment Management Company published an opinion piece this week calling for changes in the non-agency market before policymakers enact reforms that affect the government-sponsored enterprises. PIMCO was also critical of other GSE reform proposals. “Without a functioning private mortgage market, it will be nearly impossible for the GSEs to shrink their footprint without significant disruption to the housing market and to the underlying homeownership rate,” PIMCO said. PIMCO was...

July 17, 2017

Bureau Issues Proposed Rule to Address TRID’s ‘Black Hole’

In addition to the so-called TRID 2.0 final rule, the CFPB recently issued a notice of proposed rulemaking related to what’s known in the mortgage industry as TRID’s “black hole,” which refers to situations in which a lender is not permitted to use a closing disclosure to reset fee tolerances. More specifically, the proposal addresses when a creditor may use a Closing Disclosure (CD), instead of a Loan Estimate (LE), to determine if an estimated closing cost was disclosed in good faith and within tolerance. Currently, lenders are permitted, under certain limited circumstances, to use revised estimates, instead of the estimate originally disclosed to the borrower, to compare to the charges actually paid by or imposed on the borrower in...

July 17, 2017

CFPB Codifies Final Changes to TRID, Permits Sharing of the CD

The CFPB recently published long-awaited updates to its “Know Before You Owe” integrated disclosure mortgage rule, finalizing, among other things, amendments on finance charge disclosures, disclosures tied to housing assistance that a borrower receives, and when information can be shared with third parties, including real estate agents. The KBYO rule took effect in early October 2015 as part of an effort to simplify disclosures under two laws: the Truth in Lending Act and the Real Estate Settlement Procedures Act. The lending industry commonly refers to the combined disclosures as TRID, short for TILA/RESPA Integrated Disclosure rule. In a statement on the amendments, the CFPB noted that TRID “changed the total of payments calculation so that it did not make specific...

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