HOEPA now, too:
http://files.consumerfinance.gov/f/201207_cfpb_proposed-rule_high-cost-mortgage-protections.pdf

Haven't started yet, but I usually read the actual regulation (proposed) first, then definitions (tie them back to regulation), then go back and read the preample and discussion which gives more detail and the "why" of what is proposed.

Good idea. This is my first "new" regulation, so I'm just reading it like a book.
Any help on page numbers? I'm lost.

1099 pages to the proposed reg + 533 for Know B4 You Owe + 153 for the Small Bus Panel comments + 293 for HPML stuff! Buy stock in a paper company real fast. What ever happened to the Paperwork Reduction Act? This is insane!

From the HOEPA proposal:

Effective date
The Bureau’s proposal seeks comment on when a final rule should be effective. Because the final rule will provide important benefits to consumers, the Bureau seeks to make it effective as soon as possible. ... In addition, industry will at approximately the same time be implementing a number of other changes relating to other Dodd-Frank Act provisions, some of which will take effect within one year after issuance of final implementing rules...

And since the RESPA/TIL proposal states they wish to release fonal rules in January, I am guessing TIL/RESPA will be mandatory somewhere between January 1 and Januray 21 of 2014.

Here's the CFPB's summary of the TILA/RESPA Proposal. http://files.consumerfinance.gov/f/20120...-disclosure.pdf

The CFPB has an interactive version of the new loan estimate that if you click on part of the form it will also bring up the corresponding part of the proposed regulation. http://www.consumerfinance.gov/knowbeforeyouowe/#disclosure

I am skimming through this and tagging certain sections for further review. I found this interesting and funny. The discussion of cost of funds basically says that the Bureau and the consumers who participated in testing were confused by this (regardless of what they called it) and that there is no industry term that fits Therefore the proposal is to:

Accordingly, the Bureau is soliciting comment on both “lender cost of funds” and “average cost of funds” pursuant to its authority under TILA section 105(a), Dodd-Frank Act section 1032(a), and, for residential mortgage loans, Dodd-Frank Act section 1405(b). Proposed § 1026.38(o)(6) requires creditors to disclose the “approximate cost of funds,” using that term and the abbreviation “ACF” and expressed as a percentage, and the statement “The approximate cost of funds used to make this loan. This is not a direct cost to you.” For purposes of proposed § 1026.38(o)(6), “approximate cost of funds” means either the most recent ten-year Treasury constant maturity rate or the creditor’s actual cost of borrowing the funds used to extend the credit, at the creditor’s option. The Bureau solicits comment on whether another index, such as the London Interbank Offer Rate (LIBOR), would be a more appropriate measure of the approximate cost of funds.The Bureau also solicits comment on what would be required for creditors to disclose their actual costs of funds.

So they are giving an option of using a quoted rate - that would be easier - but I hope if LIBOR is an option that any LIBOR used would be the "real deal" and not one manipulated by some interested parties!

Wait for the Federal Register, it will probably only be 476 pages

In tiny print! i like the larger print.

This is long because it has the analysis, forms, and commentary all included.

Oh, complaint about contents?? I thought the complaints were only about the nummber of pages

Everybody better start sharpening their pens and pencels and start working on those comment letters.

For the first time that I can remember, I'm going to try to analyze this totally on the computer with highlights and comments. I usually like hard copy, but for a proposal I just ain't about wasting all those trees! I just don't like reading that much on the puter...it is painful!

Oh Joy! This is going to be fun. I can here it now....

"Wow that is quite a large tip you are giving yourself."

I find it ironic that they don't mind one bit creating 'information overload' for us to mind-boggle our way through. Again.

Joker - I am like you. I am going to try to read and make notes on the computer for this one. I am not sure how long I will last though before I give up and print it out.

It's actually easier. Bigger type and the ability to highlight and comment and have those references is working very well .

Normally, I read in an order mentioned by Kathleen above. However, since this is the first substantional writing I've read from the Bureau, I'm actually reading it like a book first (change of plan!), then will go back and break it down...at least that's my current approach!

I skimmed, highlighted and commented, and now am going back and reading specific sections. Electronically.

Which regulation (Z or RESPA) will be revised to reflect these changes? Both? I wish poorly-written and organized RESPA would go away and be incorporated into Reg. Z.

Both will be amended, at this point.

Thanks Kathleen. I've never understood why HUD has no organized commentary for RESPA, but relies on umpteen versions of FAQs and roundups.

So, I take it that this is contemplating ending the real estate exemption for purposes of figuring the finance charge? Is that right?

That's what I understand. All or most of the 4(c)(7) exemptions are going away.

Yes, there will be very few exemptions...was actually proposed by fed a few years ago.

CFPB does seem to be including commentary on RESPA. To take the place of random FAQs.

Really, its all about S I M P L I F I C A T I O N !!!

That was the "original purpose" right? Make it easier for plain folks to understand a mortgage loan and its costs.

How did they get soooooo off course with this stuff.

DC needs an enema! or It needs a good flushin!

Maybe in Nov '12.......

I guess I can understand it the more I decipher it - why it's as long as it is...I mean really...they are pretty much combining all disclosure requirements into one Reg when you get right down to it. That's cumbersome, but maybe it will be better once we absorb and accept it!

First, let's try to keep this clean and not to make this political...while not all sides like all parts, both sides jointly passed DFWSRA, and besides a very small handful of people, very few people are talking a repeal. It is what it is and it is here to stay.

Secondly, while our side of it does seem crazy complicataed, and we know in our world the difficulties we will have making it work, from the consumer side, it's not all bad. On the front end, it is one disclosure versus two, and fewer pages. It also finally tells them how much money they need to bring with them to close, and most of the terms are pretty black and white, In my shop, I see the elimination of 3-4 sheets of paper/documents on the front end alone.

And while the closing document is a little longer, it is a lot of recap of the earlies, and not much longer than a HUD and it's pages now. Yes, more information than we would like to see, and maybe more than is needed or will be read, but not all bad.