Reports from examiners and auditors indicate that a number of creditors are struggling with the requirements. Neither the requirements of Regulation B nor the requirements of Regulation Z are particularly complicated.
Recorded on June 23, 2014
New Integrated Disclosures - The Closing Disclosure
The amount of detail in the new Closing Disclosure exceeds anything in our prior experience with mortgage lending. Even though we have time to get all of the pieces in place, the time to start the process of mastering this material is now.
On "covered transactions" under the Ability to Repay Rules you are required to consider the 8 factors. But what does it really mean to consider each of the factors? What are the parameters of each of one? What do you include?