Recently, the Consumer Financial Protection Bureau issued revised versions of the small entity compliance guides for the Loan Originator Rule and the Home Ownership and Equity Protection Act ("HOEPA") Rule.
Revisions to the Loan Originator Rule Compliance Guide
The CFPB revised the compliance guide for the Loan Originator Rule in three notable respects. First, the revised guide includes a process for contacting the CFPB with informal inquiries about the rule. Second, the revised guide puts into effect the TILA/RESPA Disclosure rule. Third, and pursuant to the Economic Growth, Regulatory Relief, and Consumer Protection Act, which was adopted earlier this year, the revised guide includes an exemption from certain rules applicable to loan originators for retailers of manufactured and modular homes and their employees.
Revisions to the HOEPA Rule Compliance Guide
The CFPB made two notable revisions to the compliance guide for the HOEPA Rule. First, the revised guide broadens the exemption from the concept of a loan originator. This broader exemption should be taken into account when considering the requirement to include loan originator compensation in points and fees for purposes of the points and fees threshold under the rule. Second, the revised guide includes a process for contacting the CFPB with informal inquiries about the rule.
The revised compliance guides can be found here
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