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CFPB Special Report

CFPB Special Report. CFPB Notice & Comment: http://www.consumerfinance.gov/notice-and-comment /. FINAL RULE.

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CFPB Special Report

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  1. CFPB Special Report CFPB Notice & Comment: http://www.consumerfinance.gov/notice-and-comment/

  2. FINAL RULE Regulation B: Equal Credit OpportunityRegulation C: Home Mortgage DisclosureRegulation D: Alternative Mortgage Parity ActRegulation E: Electronic Fund TransfersRegulation F: Fair Debt Collection Practices ActRegulation G: S.A.F.E. Mortgage Licensing ActRegulation H: S.A.F.E. Mortgage Licensing ActRegulation I: Disclosure Requirements for Depository Institutions Lacking Federal Deposit InsuranceRegulation J: Land RegistrationRegulation K: Purchasers’ Revocation Rights, Sales Practices and StandardsRegulation L: Special Rules of PracticeRegulation M: Consumer LeasingRegulation N: Mortgage Acts and Practices-AdvertisingRegulation O: Mortgage Assistance Relief ServicesRegulation P: Privacy of Consumer Financial InformationRegulation V: Fair Credit ReportingRegulation X: Real Estate Settlement Procedures ActRegulation Z: Truth in LendingRegulation DD: Truth in Savings Transfer of Regulations to the CFPB Designated Transfer Date Notice: https://www.federalregister.gov/articles/2010/09/20/2010-23487/designated-transfer-date

  3. FINAL RULE International Remittance Transfers • Transfer of funds from someone in the U.S. to a designated recipient in a foreign country. • Credit unions that send more than 100 International Remittance Transfers (IRT’s) in a year must comply. • Monitoring IRT’s will be important IRT Final Rule: http://www.consumerfinance.gov/regulations/final-remittance-rule-amendment-regulation-e/

  4. Ability to Repay Closed-end Mortgage Loans Consider and verify: • Income and assets relied upon in making the ability-to-repay determination; • Current employment status; • Monthly payment on the mortgage; • Monthly payment on any simultaneous mortgage; • Monthly payments for mortgage-related obligations; • Current debt obligations; Monthly debt-to-income ratio or residual income; and, • Credit history. PROPOSED RULE Ability to Repay Notice: http://www.consumerfinance.gov/pressreleases/consumer-financial-protection-bureau-seeks-further-comment-on-ability-to-repay-mortgage-rule/

  5. PROPOSED RULE Combined Mortgage Disclosures • Truth in Lending & RESPA • Loan Estimate • 7 days before closing • Closing Disclosure • 3 days before closing • Special Information Booklet • Finance Charge Calculation Combined Mtg. Disclosures: https://www.federalregister.gov/articles/2012/08/23/2012-17663/integrated-mortgage-disclosures-under-the-real-estate-settlement-procedures-act-regulation-x-and-the/

  6. High Priced Mortgage Loans PROPOSED RULE • HOEPA coverage for new purchases and HELOC’s • HOEPA triggers: • A loan’s APR exceeds the average prime offer rate by 6.5 percentage points for most first-lien mortgages, or 8.5 percentage points for subordinate lien mortgages; • A loan’s points and fees exceed 5 percent of the total transaction amount; or • The member is charged a penalty more than 36 months after closing or penalties that exceed more than 2 percent of the amount prepaid. • Fee restrictions • Assess a members ability to repay • Required counseling • Appraisal requirements for HPML: https://www.federalregister.gov/articles/2012/08/15/2012-17059/high-cost-mortgage-and-homeownership-counseling-amendments-to-the-truth-in-lending-act-regulation-z HPML Appraisal: https://www.federalregister.gov/articles/2012/09/05/2012-20432/appraisals-for-higher-risk-mortgage-loans

  7. Requirement to provide Appraisals PROPOSED RULE Appraisal – Reg. B: https://www.federalregister.gov/articles/2012/08/21/2012-20422/equal-credit-opportunity-act-regulation-b

  8. Mortgage Servicing PROPOSED RULE • “Putting the service back in servicing.” • Monthly billing statements • ARM rate change notices • Forced placed insurance guidance • Apply payments on the day received • Pre-foreclosure intervention requirements Mortgage Servicing Reg. Z: https://www.federalregister.gov/articles/2012/09/17/2012-19977/2012-truth-in-lending-act-regulation-z-mortgage-servicing Mortgage Servicing Reg. X: https://www.federalregister.gov/articles/2012/09/17/2012-19974/2012-real-estate-settlement-procedures-act-regulation-x-mortgage-servicing-proposal

  9. Mortgage Loan Originator Compensation PROPOSED RULE • MLO compensation rules • Restriction on closed-end mortgage points and fees • Ban of mandatory arbitration agreements • Bans financing premiums for credit insurance MLO Compensation: http://www.gpo.gov/fdsys/pkg/FR-2012-09-07/pdf/2012-20808.pdf

  10. Mortgage Servicing Request for Information • Certifications and designations for financial advisors and planners who assist elderly members; • Financial education and counseling for seniors; and, • Education for seniors on fraud and financial exploitation. Seniors: https://www.federalregister.gov/articles/2012/06/19/2012-14854/request-for-information-regarding-senior-financial-exploitation

  11. Thank you for joining me for this overview of the CONSUMER Financial Protection Bureau’s actions that affect your credit union.

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