It sounds a little strange. A policy created for no action. It outlines what companies must do to determine if CFPB will not take, or is not contemplating taking, supervisory or regulatory action pertaining to a specific financial product to be offered to consumers (No Action.) Pretty good deal. It’s like when you play Monopoly and you pull the get…
Tag: CFPB
CFPB Still on The Prowl
Don’t look now but among all the talk of the new Trump administration’s defanging of the CFPB, the CFPB has fined three Reverse Mortgage lenders for deceptive advertising. According to CFPB all three, American Advisors, Reverse Mortgage Solutions, and Aegean Financial used inaccurate advertising to promote their reverse mortgage product to unsuspecting seniors. That’s no so nice. According to statements…
Do TRID Changes Go Far Enough?
The comment period for the changes to the CFPB “Know before You Owe” rule, better known to the industry as TRID, was up October 18th. The industry groups, i.e. MBA, ABA, CBA, etc. all submitted their comments. Did you? CFPB proposed several changes to the TRID rules based on issues raised by the industry and others. One key element they…
In Other CFPB News; QM Safe Harbor and PHH Response
Besides the recent ruling in the PHH case, there are other things happening with the CFPB. First, some good news. Dodd-Frank requires the CFPB to review and assess the effects of any rules implemented under the Act. Accordingly, even though it’s only been 3 years since we got the QM rule, they are already hard at work evaluating its effect…
The PHH Decision – What Did It Solve?
By now, you’ve probably heard that PHH won their case against CFPB on the anti- kickback provision under RESPA. The $109 million fine imposed by CFPB Director, Richard Cordray, against PHH was also invalidated by the Court. That’s great news for PHH, but what about the rest of the industry? In the decision, the US Court of Appeals, District of…
FHFA Revised URLA Gets CFPB Seal of Approval
CFPB published notice that the new Fannie/Freddie Uniform Residential Loan Application is approved as a model form under ECOA (Publication). CFPB’s Official Approval: Regulation B § 1002.5(b) provides rules concerning requests for information about race, color, religion, national origin, or sex. Section 1002.5(c) provides rules concerning requests for information about a spouse or former spouse. Section 1002.5(d) provides rules concerning…