Compliance Blog

Written by Brandy Bruyere, Senior Regulatory Compliance Counsel

Happy Friday everyone! A couple of weeks ago, I mentioned that the CFPB recently updated its index of questions addressed in its various TILA/RESPA webcasts to include its fifth and final edition. This week the bureau updated the Questions Index again by sorting the index by subject instead of date and adding links that take you directly to a topically bookmarked version of the webcast. Here's an example from the June 17, 2014 webcast (click to enlarge):

These are clickable links that will take you to the section of the webcast so you may listen to just that topic, rather than having to pull the entire webcast and scroll through to the approximate time stamp where a question was addressed or even worse, having to listen to the entire webcast.

In the right hand column, the Questions Index itself lists which of the linked subheadings within a particular webcast contains the discussion of the indexed question. Here is an example of some of the questions addressed in these webcasts:

• What definition of application will apply to HELOCs? (May 26, 2015, click Application in the left hand column)
• Whether successors-in-interest are considered a subsequent purchaser for the purpose of the assumption disclosure? (August 26, 2014, click scope of the rule then choose the second question)
• Discussion of the treatment of secondary market Loan-Level Price Adjustments (LLPAs) (October 1, 2014, under the Loan Estimate, P. 2 heading in the right column, click Loan Costs then select either of the LLPA questions as applicable)
• Questions relating to anti-deficiency laws (November 18, 2014, click Closing Disclosure p. 5 then choose from any of the related questions)
• Is an additional 3-business-day waiting period required if the APR decreases by more than 1/4 or 1/8 percentage points? (August 26, 2014, click Disclosure/Redisclosure Timing General Rule Requirements then click this question)

If you do not choose the specific question you would like to listen to within several sections, the link will just start playing that entire section of the webcast for you. While some questions and answers addressed in these webcasts simply restate the commentary, others provide a bit of insight for some more complicated sections of the rules. The index can be a helpful way of determining if the bureau has provided any guidance on an issue that may not seem clear from the rule text, the staff commentary or Preamble to the rule.

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Four Years Young. Our mastiff, Lemmy, is a rescue from the wonderful Washington Animal Rescue League in Washington, DC so we do not know his precise birthday. Their best guess though is that he was born in August, so he is about 4 years old this month. He used to be little in the puppy pictures on the left, he was about 6 months old and 55 pounds. These days, he's 115-120 lbs. and still has no idea he's big!