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Read articles below for analysis and discussion of recent trends by BM&G’s industry experts.

Regulation Z Threshold Amounts Raised for Exempt Transactions and Points and Fees for HOEPA Loans, Effective January 1, 2013

Threshold Amount Raised for Exempt Transactions under Regulation Z In the November 21, 2012, issue of the Federal Register (77 FR 69736 – click here) the Board of Governors of the Federal Reserve System (FRB) and the Consumer Financial Protection Bureau (CFPB) published final rules amending the official interpretation and commentary to Regulations Z by increasing the threshold for exempt consumer credit transactions to $53,000, effective January 1, 2013.

NMLS 2013 Annual Renewal Period

The 2013 Renewal Period in NMLS begins November 1 and goes through December 31. The following steps will help you prepare for and complete the renewal process in NMLS. Step 1 – Prepare for the renewal process NMLS has prepared a Renewal Handbook for state-licensed company and individual users to guide them through the renewal process. The handbook will provide information on how to prepare to request renewal of licenses in NMLS. • Renewal Handbook for Companies • Renewal Handbook for Individuals Do I need to renew my license if I received my approval for licensure after November 1, 2012? See State-Specific Renewal FAQs.

Proposed Rule Integrating RESPA and TILA Disclosures for Real Property Secured Loans

On August 23, 2012, the Consumer Financial Protection Bureau (CFPB) published in the Federal Register (77 FR 51116) the following proposed rule: “Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act (Regulation X) and the Truth In Lending Act (Regulation Z).” The comment period ends on November 6, 2012, for the proposed rule’s amendments to Regulation Z and Regulation X, including proposed §§1026.1(c) and 1026.4 for which we issued a memorandum on August 24, 2012. This memo will address the proposed rule’s other amendments to Regulation X and Regulation Z and will principally focus on the integrated disclosure amendments.

Proposed Rule Amending Sections 1026.25 and 1026.36 of Regulation Z Affecting Mortgage Loan Origination, Compensation, and Licensing

In the September 7, 2012 issue of the Federal Register (77 FR 55272), the Bureau of Consumer Financial Protection (CFPB) published a proposed rule that would amend §§1026.25 (Record Retention) and 1026.36 (Prohibited Acts or Practices and certain Requirements for Credit Secured by a Dwelling) of Regulation Z that would generally:

Proposed Rule Amending Regulation Z HOEPA Loan Coverage – Comment Period Extended By Consumer Financial Protection Bureau

On August 15, 2012, this firm issued a memorandum (click here) on the proposed rule to amend the HOEPA Loan Coverage in §1026.32(a)(1)(i) and (b)(1)(i) of Regulation Z, which was published in the August 15, 2012 issue of the Federal Register by the Consumer Financial Protection Bureau (CFPB). The proposed rule’s comment period for this amendment was originally stated to end on September 7, 2012. The CFPB has reconsidered and in yesterday’s issue of the Federal Register (77 FR 54844) published a notice that it is extending the comment period for the proposed amendments to §1026.32(a)(1)(i) and (b)(1)(i) to November 6, 2012.

Proposed Rule Amending Regulation Z §1026.4 (Finance Charge) Comment Period Extended By Consumer Financial Protect Bureau

On August 24, 2012, this firm issued a memorandum on the proposed rule to amend the definition of finance charge in §1026.4 of Regulation Z, which was published in the August 23, 2012 issue of the Federal Register by the Consumer Financial Protection Bureau (CFPB). The proposed rule’s comment period was originally stated to end on September 7, 2012. The CFPB has reconsidered and in today’s issue of the Federal Register (77 FR 54843) has published notice that it is extending the comment period for the proposed amendments to §1026.4 to November 6, 2012. Except for the above extension of the comment period, all other statements in our August 24, 2012 memorandum remain unchanged.

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