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#1735478 - 08/27/12 07:07 PM CFPB proposed new combination disclosures
newyork Offline
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Will the new CFPB proposed comibnationof RESPA and regulation Z apply to all institutions ruled under FDIC? or is there only certain financial institutions that must follow the new disclosures?

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#1735482 - 08/27/12 07:09 PM Re: CFPB proposed new combination disclosures newyork
swiggles Offline
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....applies to all financial institutions. The size of the institution, though, determines who will examine for compliance.....cfpb, fdic, frb or occ.
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#1735501 - 08/27/12 07:31 PM Re: CFPB proposed new combination disclosures newyork
newyork Offline
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okay, to understand clearly, the new disclosures will apply to ALL financial institutions, regardless who the examiners are?

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#1735510 - 08/27/12 07:37 PM Re: CFPB proposed new combination disclosures newyork
Rocky P Offline
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Right - same as before.

The regulations were (for the most part) Fed Reserve regulations and you had to adhere to them even if you were FDIC or OCC
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#1735656 - 08/28/12 01:08 PM Re: CFPB proposed new combination disclosures Rocky P
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What is the effective date for the proposed combined disclosures?

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#1735685 - 08/28/12 01:42 PM Re: CFPB proposed new combination disclosures newyork
swiggles Offline
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Comments aren't due until November (except for a couple of sections, comments for which are due in October)....so it's long way off.
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#1735831 - 08/28/12 05:01 PM Re: CFPB proposed new combination disclosures newyork
Need Coffee Offline
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For clarity sake, the deadline for the comments are November for most and September 7 for a few very important sections.
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#1735859 - 08/28/12 05:29 PM Re: CFPB proposed new combination disclosures Need Coffee
swiggles Offline
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Oh sorry....I can't read my own notes....yes....September 7th (not October!!) for 1026.1(c) and 1026.4. The rest of Reg Z and the RESPA amendments.....November 6th.
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#1736413 - 08/29/12 08:10 PM Re: CFPB proposed new combination disclosures newyork
John Burnett Offline
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The Bureau has a "drop dead date" for finalizing the regulation in January 2013. If it fails to meet that date, the requirements of Title XIV of Dodd-Frank will become effective without the regulation -- something that no one wants to see.

When the final rule is issued, the Bureau may insert a future mandatory compliance date up to a year later.
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#1736704 - 08/30/12 03:59 PM Re: CFPB proposed new combination disclosures John Burnett
MN Banker Offline
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Originally Posted By: John Burnett
The Bureau has a "drop dead date" for finalizing the regulation in January 2013. If it fails to meet that date, the requirements of Title XIV of Dodd-Frank will become effective without the regulation -- something that no one wants to see.

When the final rule is issued, the Bureau may insert a future mandatory compliance date up to a year later.


This was always my understanding too, but then I read this in the proposal and now I'm confused (page 51145 of Federal Register, 3rd column):

"There is no statutory deadline for issuing final rules to integrate the mortgage disclosures under TILA and RESPA, and the Bureau expects that it may take some time to conduct quantitative testing of the forms prior to issuing final rules."

I feel like I must be reading that wrong, but to me it says they don't have to have the final rules for the disclosures issued by January. But, that is inconsistent with everything else I've read so now I have no idea.

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#1736714 - 08/30/12 04:08 PM Re: CFPB proposed new combination disclosures newyork
mtngrrl Offline
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I thought I understood that the Bureau plans to issue "temporary exemption" rules for several issues that have a drop dead date in January, in order to allow them a little more time.
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#1736847 - 08/30/12 06:48 PM Re: CFPB proposed new combination disclosures newyork
rlcarey Offline
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There is no "drop dead date" for the combined disclosures as there is with other sections of the regulatory changes. All they were required to do was issue proposed rules within a year of the transfer date. See Section 1032(f) of the DFA.
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