I've been wading through the five August 16th FRB press releases and have come to the "...interim rule revising disclosure requirements for closed-end mortgages." The fourth one listed for that date. I'm having a bit of a problem interpreting, thus the following:

#1] Appendix H items applicable to this interim rule begin on page 54 and run thru page 57 of the press release attachment and introduces seven tables or written clauses. The way I understand it, if we install the tables and clauses in Appendix H that are indicative to our closed-end mortgage products, I would have this interim rule covered. There's nothing else.....at least not right now. Is that correct??

#2] Will someone please tell me where and how I can find this in the Federal Register? The rule is effective 30 days "after publication" and comments on this interim rule are due 60 days after, but I can't find the publication date.

Thank you for assistance!

BL - are you referring to the H4(E) - (K) payment table disclosures? I wouldn't worry all that much about the effective date...but the mandatory compliance date is 1-30-11.

Re #2 - I don't think it's actually been published in the FR yet, at least as of 2 days ago it wasn't.

Yes, RR. I'm referring to those payment table disclosures. I think if I have those 7 items covered, I'm OK for the interim rule covered by that August 16th press release. Correct ?

I apparently missed this.

What MDIA payment table disclosures are you referring to?

Bl, I just sent you a pm.

Dan, I'll pm you my cliff notes.

and here is a link to it.

Click here to read the Federal Reserve announcement. The announcement contains a link to the interim rule.

I already sent in a comment to the Fed about this. Why they have to introduce escrow payments into the TIL disclosures is beyond me.

Thanks for the PM and the links. Don't know how but I totally missed this.

It was part of a combo pack of 5 rules issued by the Fed on August 16. Grrrrr . . .

Things are changing so fast and will continue to do so..we have to watch each others backs more than ever!

This is a huge change to the core Reg Z disclosure. I don't know how the Fed expects folks to do all the programming that's gonna be required by January 31. Plus most people will have systems freezes in place through mid-January.

The part I like is the payment streams disclosed on the printed disclosure will most likely not be the payment streams used to calculate the APR itself. So a lot of the finance charges are buried because they're not disclosed on the GFE/HUD-1 any more and now the payment streams will be hidden as well. Good luck to all the auditors trying to verify APRs.

I'm wondering how the "interface" between the loan quote (used to calculate the APR on JH) and the payment stream that ends up on the TIL, is going to work together!

I really have just torn the ruling down...I haven't thought about the core process as of yet.

From what I have read, it strikes me that loan origination software providers will need to do a lot of work between now and January, and then we'll have to test the revisions.

This rule is also one of the few regulations that I can recall where a minimum font size is mandated for part of the disclosures [see 226.18(s)(1)].

Probably in keeping with the other minimum font/bold type requirements that are involved in the other tabular formats (like open-end and credit cards)

Good point. I'm thinking there may be a little bit of confusion on MI loans. For the TIL payment stream, the MI premium will be shown with the P+I payment. However, in the new 226.18(s) grids, the MI premium will be part of the escrow payment.

Kinda odd, huh!

On the "no guarantee that you will be able to refi to lower your rate and payments"...does that look to ya'll like that applies only to certain loan types...or is that to go on everything ?(that the rule covers)

Everything covered by the regulation.

226.18(t)(1) states: "For a closed-end transaction secured by real property or a dwelling, other than a transaction secured by a consumer's interest in a timeshare plan described in 11 U.S.C. 101(53D), the creditor shall disclose a statement that there is no guarantee the consumer can refinance the transaction to lower the interest rate or periodic payments."

OK...thanks..that's what I thought I remembered, but then something made me question my thought!

The FRB discussed the 5 items from 8/16 during a recent webinar. You can access the audio and the slides from the following page.

http://www.philadelphiafed.org/bank-resources/publications/consumer-compliance-outlook/outlook-live/

I am so glad I was browsing this. It slipped by me as well.

MarkB

Does anyone know if this has been published in the Federal Register yet?

I haven't seen it in the FR yet.

These changes would seem to apply to construction loans and combined construction permanent loans, but there is absolutely no discussion of it in the final rule. Does anybody know for sure if it does apply to construction loans?

It applies to loans secured by real property or a dwelling. So it covers loans secured by real property with no dwelling.