Changed Flood Escrow Rules
Effective January 1, 2016, the flood insurance escrow requirements have been changed to require institutions to escrow premiums and fees for flood insurance required for certain designated loans that are made, increased, extended, or renewed on that date or afterwards. This Compliance Action Alert outlines updates to the flood insurance escrow requirements and how banks should comply. Download here.
TILA, RESPA Integrated Disclosure (TRID) Compliance Guide
The Dodd-Frank Wall Street Reform and Consumer Protection Act became a law in 2012, directing the newly-formed Bureau of Consumer Protection (“CFPB”) to integrate the Truth-in-Lending and RESPA disclosures. The process initiated then has culminated in what are perhaps the most sweeping changes in consumer protection regulations since the rules came into being. This paper summarizes what the new rules are, how the new forms are to be used, and what the prudent banker should be aware of as they go into effect. Download here.
Dodd-Frank Act Regulatory Mortgage Rule Change Compliance Guide
The Guide is designed to help financial institutions ensure that the right policies have been updated, the right procedures have been fixed, and the right people have been trained. It gives you a clear map for how to achieve and maintain compliance with the new rules. Download here.
The New Regulation Z Escrow Rule for Higher Priced Mortgage Loans
The new TILA Escrow Rule lengthens the period escrow accounts must be maintained under regulation Z to, at least, five years, for higher-priced mortgage loans, as well as provides exemptions for small creditors who operate primarily in rural or underserved areas. Download here.
Analysis of the New Mortgage Servicing Standards
The CFPB issued further amendments to Regulation Z as well as new amendments to Regulation X to help homeowners facing foreclosure by establishing new standards for mortgage servicing. Download here.
Analysis of the Department of Housing and Urban Development’s (HUD) Final rule for compliance with The Fair Housing Act
The Department of Housing and Urban Development’s (HUD) final rule, which significantly impacts compliance with the Fair Housing Act, provides a framework for the burden of proof that individuals must use for making and defending a claim of discrimination. Download here.
Interim Rule Made for Garnishment of Accounts Containing Federal Benefit Payments
A final rule has been issued that implements revisions of the interim rule for the garnishment of accounts containing federal benefit payments, which should provide financial institutions with a greater degree of comfort. Download here.
Analysis of the New Rule Limiting Mortgage Loan Originator Compensation Requirements under the Truth‐In‐Lending Act (Regulation Z)
The CFPB issued a final rule incorporating new Dodd-Frank requirements for mortgage loans secured by dwelling into existing Regulation Z requirements for loan compensation. Download here.
The Biggert‐Waters Act and the Future of Flood Compliance for the Banking Industry
Recent provisions had gone into effect, and proposed changes will go in effect, regarding the amendments of the Biggert-Waters Flood Insurance Reform Act of 2012 affecting the Flood Disaster Protection Act. Download here.