yippee!!!!!! No new date set but it will all roll out as one!!!
read about it here
Happy Friday, y'all!

I'm looking through my notes and can't find this.....would the "Title XIV" acts that are being delayed include the Force-Placement of hazard insurance rules?

From my colleague, Bart:

Check out the Breaking News on our Top Stories page. There's a link in the story to the Bureau's announcement and the actual final rule.

When you work your way through the rule and get to the actual amendment (which we've posted to Reg Z §1026.1 in BOL's Alphabet Soup section), you'll see that compliance with these sections of TILA and RESPA is being delayed:

TILA §§

• 128(a)(16) - Disclosures of monthly payment, including escrow, at initial and fully-indexed rate for variable-rate residential mortgage loan transactions.
• 128(a)(17) - Disclosure of aggregate amount of settlement charges, amount of charges included in the loan and the amount of such charges the borrower must pay at closing, the approximate amount of the wholesale rate of funds, and the aggregate amount of other fees or required payments in connection with a residential mortgage loan.
• 128(a)(18) - Disclosure of aggregate amount of mortgage originator fees and the amount of fees paid by the consumer and the creditor.
• 128(a)(19) - Disclosure of total interest as a percentage of principal.
• 128(b)(4) - Repayment analysis disclosure to include amount of escrow payments for taxes and insurance.
• 129C(f)(1) - Warning regarding negative amortization features.
• 129C(g)(2) and (3) - Disclosure of State law anti-deficiency protections.
• 129C(h) - Disclosure regarding creditor's partial payment policy prior to consummation, and, for new creditors, after consummation.
• 129D(h) - Disclosure regarding mandatory escrow or impound accounts.
• 129D(j)(1)(A) - Disclosure prior to consummation regarding waiver of escrow in connection with the transaction.
• 129D(j)(1)(B) - Disclosure regarding cancellation of escrow after consummation.

RESPA §

• 4(c) - Optional disclosure of appraisal management company fees.

Ok....the force place hazard insurance stuff is in the proposed rule on servicing practices...and that amends RESPA, not Reg. Z...therefore, this delay doesn't affect that...therefore, the servicing rule goes in effect on January 13th, 2013...do i have that right? Thanks.

If you pore over the list in the post two up from this one, you'll see that the only MRAPLA provisions that are being postponed at those involving disclosures that are related to early disclosures or loan closing disclosures. So they all are related to the integration of disclosures project. That project doesn't have a drop-dead target date because it's outside Title XIV.

The rest of Title XIV (MRAPLA) will see final rules before 1/21/13. That includes the force-place hazard insurance rules, appraisal changes, the change to Reg B appraisal copy rules, origination standards, qualified mortgages, monthly statements, HOEPA changes, homeowner counseling, etc.

Thanks John. So we're going to see a ton of final rules in the next 2 months for sure? There's no worry of any of those going into effect on 1-21-13 because the final rules don't get done in time?

The Bureau has said that it does not want that "steamroller" trigger provision to be used, so it's committed to final rules before 1/21. Even Raj Date's announced departure won't happen until the final rules are issued. I think we have to take the Bureau at its word on that. But the compliance dates can't be delayed beyond one year from the date the final rules are issued, according to the DFA.

Thanks again.

Does anyone know of a list of proposed rules that were to be self-effectuating on 1/21/13? I see in this thread that the CFPB has backed off on a bunch in Reg Z/RESPA - but I'm wondering if there are others that we should be monitoring in case final rules do not come out?

Tarhe,
I have been using this calendar to help me keep track. http://www.philadelphiafed.org/bank-reso...ry-calendar.cfm

OR this
http://www.aba.com/aba/documents/RegReform/EffectiveDatesChart.pdf

Thank you very much!!

Here's another one:

http://www.fdic.gov/regulations/resources/cbi/calendar.html

So...if I understand correctly, appraisal rules for the new Higher Risk Mortgage Loans and the appraisal changes under Reg. B will still be effective January 21, 2013....correct?

No. The final rules to implement those requirements must be published by that date, or the provisions will become effective without implementing rules on 1/21/13. But the Bureau intends to have those final rules out before the 1/21/13 deadline. Those rules can set an effective date any time from immediate to 12 months in the future (from the final rule date).

So it's still a "wait and see" game.

Thanks John. So lets pretend the CFPB doesn't have rules by 1/21...will banks have to "comply" with the proposed items as is until there are rules?

Technically yes, but the CFPB I do not believe will let that happen. It would look bad for the new agency to not be able to fulfill their duties and they are under intense scrutiny at this point from Congress.

Yes. Virtually all of Title XIV of Dodd-Frank, itself known as the "Mortgage Reform and Anti-Predatory Lending Act," has the steamroller effective date trigger. The CFPB has disarmed the trigger on the selected disclosure provisions, but the substantive MRAPLA provisions -- appraisal reform, loan originator compensation, anti-steering requirements, ability to repay, "qualified mortgages," high-cost mortgage amendments. escrow rule revisions, the ECOA appraisal copy rule, etc., still have the steamroller provision hanging over them if the Bureau doesn't get final rules out.

The requirement for the Bureau to come up with combined RESPA/TILA early and final mortgage loan disclosures is outside of MRAPLA, so it doesn't have a "drop dead" deadline.