No pictures today, instead a brief note about something all of us will be effected. Here is a brief breakdown: Yesterday, the Consumer Financial Protection Bureau (CFPB) released a 1099-page Proposed Rule on combining required disclosures under TILA and RESPA and a Proposed HOEPA Rule, both of which were mandated by the Dodd-Frank Act. Public comments for most provisions in the proposed RESPA-TILA rule are due November 6, 2012, with certain exceptions (see below). Comments on the proposed HOEPA rule are due on September 7, 2012. The CFPB is proposing to impose a "zero tolerance" on (1) charges for services provided by an affiliate of the lender or broker; and (2) charges for services for which the lender or broker does not permit the consumer to shop. This means that the final charges a...
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