Compliance Blog

Written by Steve Van Beek

The CFPB will be testing its "Know Before You Owe" application disclosures this week.  The CFPB's blog post also mentioned their next steps on working on the closing disclosures:

"So far, we’ve been testing a disclosure that combines the Truth in Lending form and Good Faith Estimate that you get after you apply for a mortgage loan. But what about at the other end of the transaction? When you close your mortgage, you get a new form that discloses the final terms and costs. Well, we’d like that disclosure to be just as clear and effective as the application disclosure will be, thanks to you. So, stay tuned because soon we will be sharing a prototype closing disclosure and asking for your feedback.

And, stay with us throughout this process, because this isn’t the last you’ll see of the application disclosure. It needs to work together with the closing disclosure, so we’ll be asking for your feedback on both in the future."

Remember, Dodd-Frank included a mandatory date of July, 21 2012 (one year from the designated transfer date) for the CFPB to propose combined disclosures.  This along with Raj Date's indication that the "Ability to Repay" rule might go final this spring assures mortgage changes in 2012.  

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Yesterday, we blogged on the SAFE Act renewal process.  A helpful reader (Hat Tip to Bob B.) pointed out that renewal fees won't be charged for individual MLOs in 2012 as those fees were rolled into the initial registration for this year.  

This language comes from the Federal Renewal Handbook (Page 12):

"Please note that for the 2012 renewal year there will be no MLO renewal/reactivation  processing fees. The 2012 renewal/reactivation processing fee was included in the 2011 registration processing fee." 

Also, on Page 3 is this Note:

"NOTE: There is a $100 renewal/reactivation processing fee for institutions. There is no MLO renewal/reactivation processing fee for 2012."