Thread Options
|
#1719974 - 07/13/12 05:54 PM
Re: RESPA/Reg Z Proposal Is Out
CalifDreamin
|
10K Club
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
|
I am planning on writing my first comment letter ever, based on these proposals!
That, amongst other items, will surely be included.
_________________________
I don't repeat gossip, so listen closely...
|
Return to Top
|
|
|
|
#1719998 - 07/13/12 06:22 PM
Re: RESPA/Reg Z Proposal Is Out
#Just Jay
|
Platinum Poster
Joined: Aug 2006
Posts: 980
|
I am planning on writing my first comment letter ever, based on these proposals!
That, amongst other items, will surely be included. So am I!
|
Return to Top
|
|
|
|
#1720027 - 07/13/12 07:23 PM
Re: RESPA/Reg Z Proposal Is Out
CalifDreamin
|
Power Poster
Joined: Aug 2002
Posts: 3,094
|
You add the 2 CC that are 10% tol group together. If over 10%, you can use the revised disclosure. (at least that's how I read it)
ii. Assume a creditor receives information on Monday that, because of a changed circumstance under § 1026.19(e)(3)(iv)(A), the title fees will increase by an amount totaling six percent of the originally estimated settlement charges subject to § 1026.19(e)(3)(ii). The creditor had received information three weeks before that, because of a changed circumstance under § 1026.19(e)(3)(iv)(A), the appraisal fees increased by an amount totaling five percent of the originally estimated settlement charges subject to § 1026.19(e)(3)(ii). Thus, on Monday, the creditor has received sufficient information to establish a valid reason for revision and must provide revised disclosures reflecting the 11 percent increase by Thursday to comply with § 1026.19(e)(4)(i).
_________________________
Opinions are my own and not of my employer.
|
Return to Top
|
|
|
|
#1720774 - 07/17/12 06:52 PM
Re: RESPA/Reg Z Proposal Is Out
CalifDreamin
|
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
|
I went on vacation and come back and find these new proposals! I think I would like to go back on vacation!
|
Return to Top
|
|
|
|
#1726336 - 08/02/12 01:13 PM
Re: RESPA/Reg Z Proposal Is Out
ahkcompliance
|
Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
|
Anyone have an idea on how long it takes for a proposal to be published in the Federal Register? I keep checking for this one, but nothing's there.
_________________________
Management is doing things right; leadership is doing the right things. Peter Drucker
|
Return to Top
|
|
|
|
#1728075 - 08/07/12 03:26 PM
Re: RESPA/Reg Z Proposal Is Out
Sinatra Fan
|
Gold Star
Joined: Dec 2006
Posts: 435
TN
|
If memory serves me correctly, it's usually been about 2 weeks in the past, which means these are past due.
Why am I not surprised?
_________________________
____________________________________ Keep Calm and Carry On CRCM
|
Return to Top
|
|
|
|
#1728331 - 08/07/12 08:57 PM
Re: RESPA/Reg Z Proposal Is Out
Sinatra Fan
|
Power Poster
Joined: Nov 2000
Posts: 2,701
PA
|
John Burnett posted this in the Financial Reform Forum earlier today It appears that the Bureau's 1,099-page proposal to integrate RESPA and TILA disclosures will be published on August 23, a mere 15 days prior to the first of its two comment deadlines (September 7). So if you're waiting to see the small-print version that saves trees, your window for review will be really tight if you wish to comment on (1) the proposal to delay certain DFA disclosures, or (2) the revised APR calculation. The rest of the proposal has a November 6 comment deadline.
_________________________
Opinions expressed are mine and not necessarily those of my employer.
|
Return to Top
|
|
|
|
#1728463 - 08/08/12 01:09 PM
Re: RESPA/Reg Z Proposal Is Out
Deena
|
Gold Star
Joined: Dec 2006
Posts: 435
TN
|
From BOL today:
• Bureau sets publication dates for proposals For those waiting for the “small-print” versions, the CFPB has scheduled the Federal Register publication dates for its two recently proposed mortgage loan rules amending Regulations X and Z. o August 15, 2012: High-cost mortgage and homeownership counseling o August 23, 2012: Integrated mortgage disclosures
_________________________
____________________________________ Keep Calm and Carry On CRCM
|
Return to Top
|
|
|
|
#1728472 - 08/08/12 01:19 PM
Re: RESPA/Reg Z Proposal Is Out
CalifDreamin
|
Power Poster
Joined: Aug 2002
Posts: 3,094
|
Under the proposed rule, the preamble states that failure to disclose homeowner's ins on the estimate is not in "good faith". Since this is an item that is not subject to tolerances, what are we suppose to do?
_________________________
Opinions are my own and not of my employer.
|
Return to Top
|
|
|
|
#1728478 - 08/08/12 01:26 PM
Re: RESPA/Reg Z Proposal Is Out
CalifDreamin
|
10K Club
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
|
Quote for it, like we have had to do for purchases since the GFE was revised two and a half years ago.
_________________________
I don't repeat gossip, so listen closely...
|
Return to Top
|
|
|
|
#1728498 - 08/08/12 01:56 PM
Re: RESPA/Reg Z Proposal Is Out
CalifDreamin
|
Power Poster
Joined: Aug 2002
Posts: 3,094
|
I was talking about an inadvertent error.
_________________________
Opinions are my own and not of my employer.
|
Return to Top
|
|
|
|
#1728826 - 08/08/12 06:30 PM
Re: RESPA/Reg Z Proposal Is Out
CalifDreamin
|
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
|
I have been going through the proposed rule and have a question on the new definition of finance charge/APR. I have read two articles that kind of contradict one another. Are the following items under the new proposed rules considered part of the finance charge/APR?
1026.4(c) (7) Real-estate related fees. The following fees in a transaction secured by real property or in a residential mortgage transaction, if the fees are bona fide and reasonable in amount:
(i) Fees for title examination, abstract of title, title insurance, property survey, and similar purposes.
(ii) Fees for preparing loan-related documents, such as deeds, mortgages, and reconveyance or settlement documents.
(iii) Notary and credit-report fees.
(iv) Property appraisal fees or fees for inspections to assess the value or condition of the property if the service is performed prior to closing, including fees related to pest-infestation or flood-hazard determinations.
(v) Amounts required to be paid into escrow or trustee accounts if the amounts would not otherwise be included in the finance charge.
|
Return to Top
|
|
|
|
#1728884 - 08/08/12 07:20 PM
Re: RESPA/Reg Z Proposal Is Out
ahkcompliance
|
Power Poster
Joined: Aug 2002
Posts: 3,094
|
The 4(c)(7) charges are finance chgs for closed-end cr but not for HELOCs. At least that's the way I understand it.
_________________________
Opinions are my own and not of my employer.
|
Return to Top
|
|
|
|
#1728901 - 08/08/12 07:33 PM
Re: RESPA/Reg Z Proposal Is Out
CalifDreamin
|
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
|
That is what I thought as well.
|
Return to Top
|
|
|
|
#1729368 - 08/09/12 06:28 PM
Re: RESPA/Reg Z Proposal Is Out
CalifDreamin
|
10K Club
Joined: Nov 2002
Posts: 20,654
The Swamp
|
Agree.
_________________________
My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
|
Return to Top
|
|
|
|
|
|