On July 9, 2012, the Consumer Financial Protection Bureau (CFPB) issued two Notices of Proposed Rulemaking (NPRs) to implement key residential mortgage reforms of the Dodd-Frank Act. We briefly describe these proposals – which total almost 1400 pages combined -- and will address some of their key changes in subsequent FS Regulatory Briefs.
The High-Cost Mortgage and Homeownership Counseling NPR, proposes to amend Regulation Z (Truth-in-Lending Act) and Regulation X (Real Estate Settlement Procedures Act) to implement provisions of Dodd-Frank relating to the Home Ownership and Equity Protection Act (HOEPA) provisions of Regulation Z and the homeownership counseling provisions of Regulation X. The second NPR is an Integrated Mortgage Disclosures proposal to implement “Know Before You Owe” disclosures.
At what is still just the beginning of the expected flow of proposed mortgage-related CFPB rules, we also step back and consider how best to meet this avalanche without getting buried.