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ICBA’s TILA-RESPA disclosure compliance resource, and more

ICBA Provides Summary of TILA-RESPA Integrated Disclosure Rule

ICBA has released a summary of the TILA-RESPA Integrated Disclosure rule. The 12-page summary covers the Consumer Financial Protection Bureau’s final rule that amends the Truth in Lending Act’s Regulation Z and the Real Estate Settlement Procedures Act’s Regulation X to integrate mortgage loan disclosures.

While this rule includes major changes to mortgage loan disclosures and delivery requirements, due to ICBA advocacy, no proposed changes requiring creditors to disclose an all-inclusive annual percentage rate were finalized. The new integrated disclosures must be provided by creditors or mortgage brokers that receive consumer applications for closed-end credit transactions secured by real property on or after Aug. 1, 2015.

Find ICBA’s summary online under at www.icba.org/mortgagerules.


ICBA Quick Poll: Expanding Tiered Regulation

Federal Reserve Chair Janet Yellen said her agency is taking steps to avoid a one-size-fits-all approach to bank regulation. Do you expect regulators to continue working toward regulations that are tiered to the size and complexity of affected institutions?

Yes: 47%
No: 42%
Don’t Know: 11%

Source: ICBA NewsWatch member poll, May 2014


Notable Quotes

On mortgage-servicing regulation…

“The agencies should be encouraging community banks to retain the mortgage-servicing rights of the loans they originate. Community banks are uniquely adept at providing a level of customer service that takes into account the financial condition of the borrower and their ability to meet the required loan covenant and payment obligations.”
—ICBA letter to the Consumer Financial Protection Bureau

“These new [Basel III] burdensome prohibitions on regulatory capital are sending a clear message to community banks that they should not be servicing the mortgages they originate for their customers. … Rather, the agencies should be encouraging community banks to retain the servicing rights of the loans they originate.”
—ICBA letter to the banking agencies

On housing-finance reform bill…

“The community banking industry remains concerned with how the legislation would work in the real-world marketplace and whether it would cause further market concentration of the housing-finance system into a few of the largest financial institutions.”
—Camden Fine, ICBA president and CEO

On proportional regulation…

“It would be worthwhile to have a policy discussion of statutes that might be amended explicitly to exclude community banks (which, again, are generally defined as those with less than $10 billion in assets) from their coverage.”
—Daniel Tarullo, Federal Reserve Board governor

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