Author Archives: Jack Holzknecht

POINTS AND FEES – INDEX RATE FOR PERSONAL PROPERTY

Posted on January 2, 2014 by Jack Holzknecht

When calculating points and fees §1026.32(b)(1)(i)(E and F) allow the creditor to exclude from the calculation up to two bona fide discount points under §1026.32(b)(1)(i)(E), or up to one bona fide discount point under §1026.32(b)(1)(i)(F),  paid by the consumer in … Continue reading →

Posted in CFPB, Dodd-Frank Act, Financial Reform, Lending Compliance, Regulation Z, Truth in Lending | Tagged , , , , | 1 Comment

Happy New Year

Posted on December 31, 2013 by Jack Holzknecht

This has been a year to remember. Unprecedented regulatory change (over 6,000 pages) have ruled the day. It appears that 2014 will also be a busy year, but we hope the pace and volume of change is more reasonable. All … Continue reading →

Posted in Uncategorized | 1 Comment

FLURRY OF YEAR-END THRESHOLD ADJUSTMENTS

Posted on December 31, 2013 by Jack Holzknecht

The Consumer Financial Protection Bureau (CFPB) just completed the usual year-end chore of updating various thresholds. The changes are based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers … Continue reading →

Posted in CFPB, HMDA, Lending Compliance, Regulation C, Regulation Z, Truth in Lending | Tagged , , , , , | Leave a comment

HMDA – HOEPA STATUS

Posted on December 30, 2013 by Jack Holzknecht

Section 1003.4(a)(13) of Regulation C requires that the Loan Application Register indicate, among other items, whether the loan is subject to the Home Ownership and Equity Protection Act of 1994 (HOEPA), as implemented in Regulation Z (12 CFR 1026.32). Under … Continue reading →

Posted in CFPB, Dodd-Frank Act, Financial Reform, HMDA, Lending Compliance, Regulation C, Regulation Z, Truth in Lending | Tagged , , , , , , | Leave a comment

CFPB – A LOOK AHEAD AT 2014

Posted on December 24, 2013 by Jack Holzknecht

It appears that the Consumer Financial Protection Bureau (CFPB) will be busy during 2014, but a lot less busy than 2013. On December 3, 2014 the CFPB published a semi-annual update to its rulemaking agenda. The fall 2013 agenda reflects … Continue reading →

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REVISED HPML APPRAISAL RULES

Posted on December 13, 2013 by Jack Holzknecht

On December 12, 2013 the Federal Reserve Board, The Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the National Credit Union Administration, and the Office of the Comptroller of the Currency jointly published a … Continue reading →

Posted in Appraisal Rules, CFPB, Dodd-Frank Act, FDIC, Federal Reserve Board, Financial Reform, Lending Compliance, Regulation Z, Truth in Lending | Tagged , , , , , | Leave a comment

HUD PUBLISHES FINAL QM RULE

Posted on December 12, 2013 by Jack Holzknecht

On December 11, 2013 the Department of Housing and Urban Development (HUD) published a final rule to establish a definition of “qualified mortgage” (QM) for the single family residential loans that HUD insures, guarantees, or administers that aligns with the … Continue reading →

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NEW INTEGRATED DISCLOSURES RELEASED

Posted on November 20, 2013 by Jack Holzknecht

On October 20, 2013 the Consumer Financial Protection Bureau published the new rules for the integrated disclosures. The new rule is 1,888 pages long and is effective on August 1, 2015. The CFPB is not revising finance charge rules at this … Continue reading →

Posted in CFPB, Dodd-Frank Act, Integrated Disclosures, Integrated Disclosures, Regulation X, Regulation Z, RESPA, Truth in Lending | Tagged , , , , , , | Leave a comment

KNOW BEFORE YOU OWE: MORTGAGES

Posted on November 20, 2013 by Jack Holzknecht

As we recently reported, today is a big day for mortgage lenders. The Consumer Financial Protection Bureau (CFPB) is releasing the new integrated disclosures in conjunction with a field meeting scheduled at 11:00 a.m. in Boston. The new Loan Estimate … Continue reading →

Posted in CFPB, Dodd-Frank Act, Lending Compliance, Regulation X, Regulation Z, RESPA, Truth in Lending | Tagged , , , , , , | Leave a comment

HOMEOWNERSHIP COUNSELING ORGANIZATIONS LISTS

Posted on November 14, 2013 by Jack Holzknecht

Section 1024.20(a)(1) of Regulation X requires lenders to provide the loan applicant with a written list of homeownership counseling organizations that provide relevant services in the loan applicant’s location. The rule is effective on January 10, 2014. On November 7, … Continue reading →

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