By: Timothy A. Raty, Sr. Regulatory Compliance Specialist
“TWICE, adv. Once too often.” (Ambrose Bierce, Devil’s Dictionary)
On June 9, 2020 the CFPB published the following Q&A on their “TILA-RESPA Integrated Disclosure FAQs” webpage:
“Can a creditor require a consumer to sign and return the Loan Estimate or Closing Disclosure?…
By: Timothy A. Raty, Sr. Regulatory Compliance Specialist
“consent . . . a voluntary yielding to what another proposes or desires;
agreement, approval, or permission regarding some act or purpose, esp.
given voluntarily by a competent person;…
By: Timothy A. Raty, Sr. Regulatory Compliance Specialist
“Knowledge is contextual . . . By ‘context’ we mean the
sum of cognitive elements conditioning the acquisition,
validity or application of any item of human knowledge….
By: Timothy A. Raty, Sr. Regulatory Compliance Specialist
Date: March 26, 2020
“No technological computation and calculation would
be possible in an environment that would not employ a
generally used medium of exchange, money.”
(Ludwig von Mises,…
By: Timothy A. Raty, Sr. Regulatory Compliance Specialist
Earlier this month, the Federal National Mortgage Association (“FNMA”) and Federal Home Loan Mortgage Corporation (“FHLMC”) announced some of their plans for the gradual elimination (and replacement) of their adjustable-rate mortgages (“ARMs”) programs,…
“’What do you want?’ the ape asked at last.
‘Nothing,’ said Ervic.
‘You may have that!’ retorted the ape.” (Glinda of Oz, L. Frank Baum)
_______________________
Section 309 of the Economic Growth,…
By: Timothy A. Raty; Sr. Regulatory Compliance Specialist
“mortgage insurance (1876) . . . 2. An agreement to provide money to
the lender if the mortgagor defaults on the mortgage payments. – Also
termed private mortgage insurance (PMI).” (INSURANCE,…
By: Timothy A. Raty; Sr. Regulatory Compliance Specialist
“Arrakis teaches the attitude of the knife –
chopping off what’s incomplete and saying:
‘Now it’s complete because it’s ended here.’” (Dune)
Under TRID 2.0,…
By: Timothy A. Raty; Sr. Regulatory Compliance Specialist
“This thing is like an onion. The more layers you peel, the more it stinks.” (George Costanza, Seinfeld, Season 8: The Soul Mate)
One of the more intriguing conundrums of TRID (particularly TRID 2.0) is 12 CFR § 1026.38(j)(1)(v),…
By: Timothy A. Raty; Sr. Regulatory Compliance Specialist
An overlooked aspect of the Economic Growth, Regulatory Relief, and Consumer Protection Act (“EGRRCPA”; 132 Stat. 1296 [2018]), Section 309 (aka “The Protecting Veterans from Predatory Lending Act”),…
By: Timothy A. Raty, Sr. Regulatory Compliance Specialist
Per 12 CFR § 1026.37(o)(4)(i)(A), the dollar amounts required to be disclosed in the “Lender Credits” row of Section J of the Loan Estimate (“LE”) are required to be rounded to the nearest dollar….
By Timothy A. Raty, Sr. Regulatory Compliance Specialist
On May 24th, President Donald J. Trump (R) and a Republican Congress (with a fair number of Democratic and independent support), passed into law the “Economic Growth, Regulatory Relief, and Consumer Protection Act” (“EGRRCPA”),…
By: Timothy A. Raty, Sr. Regulatory Compliance Specialist
During the implementation of the “Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z)” (78 FR 79730 [2013]; commonly referred to as “TRID” or “TRID 1.0”) between 2012 and 2015,…
By: Timothy A. Raty, Sr. Regulatory Compliance Specialist
One of the unique changes made under the “Amendments to Federal Mortgage Disclosure Requirements Under the Truth in Lending Act (Regulation Z)” (82 FR 37656 [2017]; commonly referred to as “TRID 2.0”) is that creditors will need to disclose the amounts of post-consummation inspection and handling fees with the “Loan Estimate” (LE) and “Closing Disclosure” (CD;…
By: Timothy A. Raty, Sr. Regulatory Compliance Specialist
On both the Loan Estimate and the Closing Disclosure (required to be provided under Federal Regulation Z and collectively referred to as “Integrated Disclosures”), creditors must disclose “a statement detailing any charge that may be imposed for a late payment,…
Loan applications may appear to be straightforward documents,…
Timothy A. Raty
On July 25, 2017, the House of Representatives passed H.J. Res. 111 (2017), which states the following:
“Resolved by the Senate and House of Representatives of the United States of America in Congress assembled,…
The long-awaited amendments to the TILA-RESPA Integrated Disclosure Rule (“TRID 2.0”) were finally released by the CFPB on July 7, 2017 (see https://www.consumerfinance.gov/about-us/newsroom/cfpb-finalizes-updates-know-you-owe-mortgage-disclosure/). Many of the proposed rules were finalized with revisions (most of which are either minor in detail or provide further clarifications)….
Timothy A. Raty
“All laws must be objective (and objectively justifiable): men
must know clearly, and in advance of taking an action, what the
law forbids them to do (and why), what constitutes a crime and
what penalty they will incur if they commit it.”
(Ayn Rand,…
“A trust ….
