July 8, 2015
TDI Adopts Texas Disclosure Rule and Form
Will be Required With New CFPB Federal Closing Disclosure Beginning in October
The Texas Department of Insurance (TDI) has posted
notice of adoption of the proposed Texas Disclosure Rule on its website. Technically, the effective date of the new
Texas Disclosure Rule will be Aug. 1, 2015. However, the rule only requires the use of the form when the CFPB requires its new Closing Disclosure which will not be until October.
TDI held hearings on the new Texas Disclosure rule in May. The
new rule and
form were designed to be used in conjunction with the new federal Closing Disclosure that is now recommended to go into effect in October of this year. For more background, click here.
Check here later this week to view the On Demand version of TLTA’s webinar “The Texas Disclosure - What Goes On It & How To Explain It.”
TLTA Legislative Report Now Available
The 84th Texas Legislative Session was a busy one for TLTA. We brought a relatively modest affirmative agenda to the Legislature, which turned out to be a wise decision as there were several complex pieces of legislation brought by other parties which greatly affected the title industry and which required significant engagement and work on behalf of TLTA’s lobby team and volunteer leaders.
This comprehensive, post-session report contains the TLTA affirmative agenda and the legislation that has an effect on the title industry and your business.
TLTA Provides CFPB Comment Letter
TLTA President Patti Bonner recently sent a letter to CFPB’s Office of the Executive Secretary supporting the CFPB’s proposed rule to delay the effective date of both the TILA‐RESPA Final Rule and the TILA‐RESPA Amendments to October 3, 2015. “We concur with this finding,” said Bonner. “We believe the title industry was largely prepared for the implementation date, however, many of our partners in the lending and real estate communities were dependent on third parties that were not as far ahead.”
The letter also raised two issues related to the TILA-RESPA Final Rule and Amendments. The first supports a “hold harmless” period of enforcement following the proposed Oct. 3rd effective date. The second issue relates to the fact that the present disclosure forms do not reflect state law and the requirements that consumers benefit from a reduced cost of title insurance for simultaneous issuance of owner and loan policies. TLTA supports modifying the Official Interpretations to allow the title industry to disclose title premiums as they are actually charged according to state law and based on the same standards they must use for disclosing all other costs.
To read the full letter,
click here.
CFPB Indicates How to Disclose Title Insurance Premiums in Seller-Pay Scenarios
ALTA Blog | June 24,2015
Since announcing the TILA-RESPA Integrated Disclosure rule in 2013, the Consumer Financial Protection Bureau has hosted a series of webinars to address frequently-asked questions regarding the new rule’s requirements. On May 26, the CFPB hosted its fifth TILA-RESPA Integrated Disclosures webinar. Click here to listen to a recording of the webinar and to download a copy of the presentation.
Read more here.
What to Expect When You're Expecting a CFPB Administrative Action
HousingWire | July 6, 2015
In early June, Consumer Financial Protection Bureau Director Richard Cordray issued a decision in the first appeal of an agency administrative enforcement proceeding. Cordray's ruling in the administrative action against PHH Corp. could have a long-term impact enforcement actions by the CFPB in the future.
Read more here.
The Top 5 Things to Know About TRID Now
Mortgage Compliance Magazine | June 22, 2015
ALTA's Steve Gottheim, NAR's Ken Trepeta and Joshua Weinberg of First Choice Loan Services offer what they believe to be the top five TILA-RESPA Integrated Disclosure compliance issues for settlement agents, real estate agents and lenders.
Read more here.
CFPB Asks For Comments on Enhanced Consumer Compliant Database
HousingWire | July 1, 2015
The Consumer Financial Protection Bureau (CFPB) has issued a request for information regarding its consumer complaint database after going live with an enhanced version of the database last week, according to the CFPB.
Read more here.