CFPB's Reg Z Program

Posted By: Combustible

CFPB's Reg Z Program - 05/06/15 02:07 PM

We're using CFPB's exam procedures, and they ask if the MLO's and the bank's NMLS# are on the note and security agreement. I know it isn't effective until 8/2015, so should I write up if I find any prior to the effective date? Our docs are set up and the bank's number is hard coded, but for the MLO the docs have two blank lines for the MLO to complete with NMLS#s. I know different regulators have quirks and don't want to be criticized for not following their program, so just wondering what I should do in the event an MLO hasn't complied.
Posted By: ahou

Re: CFPB's Reg Z Program - 05/06/15 03:19 PM

It is already required on the note & security agreement. It will be also be required on the LE and CD on Aug 1st
Posted By: Combustible

Re: CFPB's Reg Z Program - 05/06/15 03:31 PM

Not sure was an LE or CD is?
Posted By: NSF, CRCM

Re: CFPB's Reg Z Program - 05/06/15 03:34 PM

LE = Loan Estimate and CD = Closing Disclosure.

These are the new integrated disclosures coming in to play on 8/1/2015.

Read through 1026.37 and 1026.38 for more information
Posted By: Combustible

Re: CFPB's Reg Z Program - 05/06/15 03:40 PM

Aha, thanks. According to BOL's Reg Z 1026.36(g):

Editor's Note: Effective August 1, 2015, paragraph (g)(2)(ii) is amended to read as follows:
(ii) The disclosures required by § 1026.19(e) and (f);
(iii) The note or loan contract; and
(iv) The security instrument.

I take that to read it is not in effect yet?
Posted By: NSF, CRCM

Re: CFPB's Reg Z Program - 05/06/15 03:50 PM

Currently 1026.36(g)(2) reads as:

(2) The loan documents that must include the names and NMLSR IDs pursuant to paragraph (g)(1) of this section are:

(i) The credit application;

(ii) [Reserved]

(iii) The note or loan contract; and

(iv) The security instrument.

After 8/1/2015 it will read:

(2) The loan documents that must include the names and NMLSR IDs pursuant to paragraph (g)(1) of this section are:

(i) The credit application;

(ii) The disclosures required by § 1026.19(e) and (f);

(iii) The note or loan contract; and

(iv) The security instrument.

So currently this information has to be on the credit application, note and security instrument.

Posted By: Combustible

Re: CFPB's Reg Z Program - 05/06/15 04:00 PM

Ok, I get it now. Thanks so much! Really am glad I asked!