Posts on mortgage compliance and industry regulation including TRID, HMDA, and MERS.
Since Richard Cordray’s departure as CFPB Director and after a brief power struggle surrounding the appointment of Michael Mulvaney as Acting Director, CFPB started making some changes. In January, they issued notification of a series of Requests for Information (RFIs) to obtain comment to help determine if they are properly fulfilling their obligation to protect consumers. The RFIs to date…
In case you haven’t heard, there are some changes going on down at the CFPB. The new Administration is trying to foster a more business-friendly atmosphere while maintaining the CFPB’s mission of consumer protection. Can it be done? Only time will tell. The conversation, or should I say debate, has begun. With Mulvaney now as Acting Director, moves are being…
The CFPB is welcoming the new year with a change of heart on the collection of the new HMDA data. According to Acting Secretary Mulvaney, CFPB will offer lenders a safe harbor from enforcement action arising from reporting errors for the new 2018 data. A big win for lenders! Further, according to Mulvaney, the CFPB plans to reduce the burdens…
Better late than never, I guess. The Community Home Lenders Association sent a letter to acting CFPB Director Mulvaney seeking a delay in implementation of the new HMDA data collection and reporting requirements. That’s like betting on a long shot. They believe the new requirements are an unfair burden on small independent lenders. Further, they want a safe harbor from…
TILA requires a lender to provide an applicant with a good faith estimate of the fees that will be charged to, or imposed on, the applicant in connection with their loan. Seems simple, if you’re gonna charge it; disclose it. There’s a little catch, the fee must be for a service that is actually provided by the lender. For example:…
The debate rages on. Who will really benefit from the current tax reform proposals? Some say the rich, some say the middle class, and others say the big corporations. Maybe, it’s all three. One big question revolves around the elimination of the SALT deductions. Critics argue this is “double taxing” that would hurt the middle class. Others say, not so…
