Recent Activity
Regulation Z Proposed Rule – Escrow Requirements
Regulation Z Final Rule – Escrow Requirements
Historical Activity
What: The Federal Reserve Board (FRB) published final regulations to toughen Reg Z restrictions on mortgage lenders
- Establishes a new category of loans—higher-priced mortgage loans
- Establishes requirements/restrictions relating to higher-priced mortgage loans (escrow requirements, limits on prepayment penalties, underwriting requirements) See escrow section
- Includes additional restrictions that are applicable to all consumer mortgage loans secured by a principal dwelling (advertising, servicing)
- Broadens the scope of early Truth-in-Lending disclosures
- Only a reasonable fee to obtain a credit report may be collected from the borrower until the borrower has received the “early” TIL disclosure
Effective: October 1, 2009 (Delayed effective date for escrow requirements: April 1, 2010, for residential real property, October 1, 2010, for manufactured homes, trailers, boats, etc.)
Solutions:
Software solutions to test loans
Resources to develop your policies and procedures
Staff training
