What Has Amy K Been Up To, Anyway?
by Amy Kleinschmit, Director of Compliance
Whoever had the New Year’s Resolution to read more compliance material will have their opportunity this year. We are not even through January yet, but the CFPB has already issued seven final rules, which if you were to print them out, it would take more than 3000 pages – ok, this is the double spaced version that is issued before it is published in the Federal Register, but when my boss asks what I am working on, it is reading the 3000+ pages of new final rules. Also, to be fair it was expected that these rules would come out before January 21, 2013; otherwise the provisions in the Dodd-Frank Act would have become effective on that date without implementing regulations. As you will note below, most of these are effective next January in 2014, except for the rule on Regulation Z - Escrow Requirements which is effective June 1, 2013, and a portion of the rule relating to loan originator compensation. Look for summaries of all these rules in upcoming Memo articles (find a summary of the escrow rule in today’s Memo), but it is 3000+ pages of reading, we are working on it. These final rules do not contain the disclosure revisions to TILA and RESPA and other pending disclosure requirements; we will probably see those later this year.
Final Rule | Effective | Page Count |
Disclosure and Delivery Requirements for Copies of Appraisals and Other Written Valuations Under the Equal Credit Opportunity Act (Regulation B) | January 18, 2014 | 125 |
Appraisals for Higher-Priced Mortgage Loans | January 18, 2014 | 311 |
High-Cost Mortgage and Homeownership Counseling Amendments to the Truth in Lending Act (Regulation Z) and Homeownership Counseling Amendments to the Real Estate Settlement Procedures Act (Regulation X) | January 10, 2014 | 431 |
Escrow Requirements under the Truth in Lending Act (Regulation Z) | June 1, 2013 | 116 |
Ability-to-Repay and Qualified Mortgage Standards under the Truth in Lending Act (Regulation Z) | January 10, 2014 | 804 |
Mortgage Servicing Rules under the Real Estate Settlement Procedures Act (Regulation X) | January 10, 2014 | 753 |
Loan Originator Compensation Requirements under the Truth in Lending Act | Amendments to § 1026.36(h) and (i) effective June 1, 2013. All other provisions effective January 10, 2014 | 541 |
Total |
| 3081 |
Just as a visual reference, this is a stack of 2500 sheets of paper…I do not have enough sheets of paper to print off all the pages of rules that have been issued in 2013 from the CFPB alone!!
In the meantime, should you have any questions or concerns, please do not hesitate to contact Amy Kleinschmit at akleinschmit@cuad.coop or 701.214.9721.