Tag: “loan originator compensation”

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CFPB Addresses Double-Counting of Loan Originator Compensation in Points and Fees
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CFPB Issues First “Bulletin” Regarding TILA’s Loan Originator Compensation Rule

CFPB Addresses Double-Counting of Loan Originator Compensation in Points and Fees

By: Kristie D. Kully Anaxet Y. Jones

Earlier this week, the Consumer Financial Protection Bureau (“CFPB”) issued a final rule (the “Final Rule”) that attempts to fix the double-counting problem when including loan originator compensation in the points and fees calculation for Qualified Mortgages (“QMs”) and high-cost loans under Section 1026.32 (“HOEPA Loans”). Read More

CFPB Issues First “Bulletin” Regarding TILA’s Loan Originator Compensation Rule

By: Jonathan D. Jaffe

The CFPB issued its first pronouncement—which it refers to as a Bulletin—regarding the Truth in Lending Act’s (“TILA”) loan originator compensation rule (the “LO Comp Rule”). The Bulletin is noteworthy for at least two reasons: the CFPB took a practical approach to resolve the issue, and the CFPB announced that it anticipates issuing a proposed rule for public comment in the near future on the loan origination provisions in the Dodd-Frank Act. Read More

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