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CFPB Criticized for Lack of Guidance

Thursday, January 14, 2016

Our old standby for information on all-things-CFPB has slammed a new "fact sheet" issued by the agency regarding the treatment of construction-to-permanent loans under new TRID disclosure rules. CFPB (the Consumer Financial Protection Bureau) issued the two page sheet this month and Richard J. Andreano, writing in the CFPB blog of the Ballard and Spahr law firm says it "falls far short of the detailed guidance sought by the mortgage industry."

CFPB's sheet speaks first to the loan estimate and closing disclosure under the new TILA/RESPA Integrated Disclosure (Know Before You Owe) rule.  Construction-to-permanent loans are composed of a phase in which payments (usually in multiples) are made to fund construction and then a permanent phase during which payments cease and the loan begins to amortize. 

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