Updated Compliance Guides


On January 6, 2014, the CFPB updated the TILA Higher-Priced Mortgage Loans (HPML) Escrow Rule - Small Entity Compliance Guide.  This is what the CFPB had to say on the recent update:

"The Bureau updated this guide on January 6, 2014 to reflect finalized changes to the rule. The revisions amend the final rule issued January 10, 2013, which took effect on June 1, 2013. Notable changes in the October 2013 Final Rule, which take effect January 1, 2014, impacting guide content include:



On its website last week, the CFPB called the Ability-to-Repay and Qualified Mortgage rule (ATR/QM rule) "a 'back-to-basics' approach to mortgage lending that will protect consumers from the debt trap of a mortgage they can't afford" and added that it is "a common-sense approach policy that responsible lenders have already been following for decades."  This comment seems to presume that the ATR/QM rule provides the exclusive method for responsible mortgage lending.

New CFPB Bulletin


The CFPB published CFPB Bulletin 2013-10 reminding employers that they cannot require their employees to receive wages on payroll cards. The bulletin also explains some of the federal consumer protections that apply to payroll cards, such as fee disclosure, access to account history, limited liability for unauthorized use, and error resolution rights. Under Reg. E, an employer can require employees to receive their wages electronically, but the employer can't dictate the financial institution used by the employee.

CFPB Lawsuit


A lawsuit challenging the constitutionality of key provisions of the Dodd-Frank law, including the authority given to the Consumer Financial Protection Bureau (CFPB), was dismissed last week by a U.S. District Judge.  

CFPB Mortgage Reforms - Part 6


In order to provide additional clarification on the recently issued CFPB mortgage reforms, IBAT Regulatory Compliance Manager Kelly Goulart is releasing a series of white papers addressing each change contained in the seven major mortgage lending initiatives, six of which have been finalized by the CFPB (more or less).  

The sixth part of the series, focused on mortgage loan servicing requirements, is now online.


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