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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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