Proposed Private Flood Insurance Rule

The Banking Brotherhood (FRB, FDIC, NCUA, OCC, and Farm Credit Administration) are requesting comment on a joint notice of proposed rulemaking to implement provisions of the Biggert-Waters Flood Insurance Reform Act (Biggert-Waters Act) that require regulated lending institutions to accept certain private flood insurance policies in addition to policies made available by the Federal Emergency Management Agency (FEMA). The federal flood insurance statutes require regulated … Read More

Redesigned Uniform Residential Loan Application – UPDATED

The Federal Housing Finance Agency (FHFA) issued a notice regarding publication of the redesigned Uniform Residential Loan Application (URLA) form. According to the FHFA, “although final implementation of the new loan application is still more than a year away, and the application must still undergo “safe-harbor” review by the Consumer Financial Protection Bureau, we anticipate that publication of the redesigned … Read More

Browser requirements for NMLS access

The NMLS announced, that starting August 22, NMLS users who are not using internet browsers that support TLS 1.2 will need to upgrade by October 8. After October 8, users who have not upgraded their browsers will be restricted from accessing NMLS until they have downloaded a version that supports TLS 1.2.  Should you have any questions, please visit the … Read More

Loss Mitigation Principles

The CFPB and the U.S. Department of Housing both recently released principles for loss mitigations (CFPB, HUD).  The papers result from the mortgage crisis and phasing out of the Home Affordable Modification Program (HAMP).  The documents do not establish any new requirements, but outline principles that should be incorporated into loss mitigation strategies.  The CFPB outlines four principles:  accessibility, affordability, … Read More

Proposed Amendments to Regulation Z Mortgage Disclosure Requirements

The CFPB issued proposed changes to amend the KBYO/TRID rules of Regulation Z.  The CFPB states that the proposed amendments memorialize its informal guidance on various issues and includes clarifications and technical amendments.  There are a number of proposed changes in proposal, but are not intended to revisit major policy decisions so soon after the October 2015 effective date. Comments … Read More

Final Rules on Foreclosure Protections – Delinquency and Multiple Loss Mitigation Procedures

On August 4, the CFPB issued Final Rules providing foreclosure protections.  The Rules, consisting of 901 pages, address foreclosure protections, successors in interest, borrowers in bankruptcy, loss mitigation, servicing transfers, and loss mitigation applications.  The Rules consist of a number of amendments to Regulation X and Regulation Z, their respective Official Interpretations, and model forms and clauses.  Along with the … Read More

Final Rules on Foreclosure Protection – Borrower’s In Bankruptcy

On August 4, the CFPB issued Final Rules providing foreclosure protections.  The Rules, consisting of 901 pages, address foreclosure protections, successors in interest, borrowers in bankruptcy, loss mitigation, servicing transfers, and loss mitigation applications.  The Rules consist of a number of amendments to Regulation X and Regulation Z, their respective Official Interpretations, and model forms and clauses.  Along with the … Read More

Final Rules on Foreclosure Protections – Successors in Interest

On August 4, the CFPB issued Final Rules providing foreclosure protections.  The Rules, consisting of 901 pages, address foreclosure protections, successors in interest, borrowers in bankruptcy, loss mitigation, servicing transfers, and loss mitigation applications.  The Rules consist of a number of amendments to Regulation X and Regulation Z, their respective Official Interpretations, and model forms and clauses.  Along with the … Read More

Final Rules on Foreclosure Protections – Loss Mitigation Procedures

On August 4, the CFPB issued Final Rules providing foreclosure protections.  The Rules, consisting of 901 pages, address foreclosure protections, successors in interest, borrowers in bankruptcy, loss mitigation, servicing transfers, and loss mitigation applications.  The Rules consist of a number of amendments to Regulation X and Regulation Z, their respective Official Interpretations, and model forms and clauses.  Along with the … Read More

Final Rules on Foreclosure Protection – Servicing Transfers

On August 4, the CFPB issued Final Rules providing foreclosure protections.  The Rules, consisting of 901 pages, address foreclosure protections, successors in interest, borrowers in bankruptcy, loss mitigation, servicing transfers, and loss mitigation applications.  The Rules consist of a number of amendments to Regulation X and Regulation Z, their respective Official Interpretations, and model forms and clauses.  Along with the … Read More