On August 15, 2012, the Consumer Financial Protection Bureau (the “Bureau”) published a proposed rule and request for public comment in the Federal Register on changes to its Regulation Z (Truth In Lending Act) and Regulation X (Real Estate Settlement Procedures Act) to implement the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”) with respect to mortgage loans subject to the Home Ownership and Equity Protection Act of 1994 (“HOEPA”). These proposed rules were reported in this publication on August 28, 2012. As described in that publication, the comment period was to have ended September 7, 2012.
On August 23, 2012, the Bureau published proposed rules and model forms in the Federal Register that combine certain disclosures currently required by Regulations Z and X in connection with applying for and closing on a residential mortgage loan, as required by the Act. These proposed rules were reported in this publication on September 6, 2012. As described in that publication, the comment period ends November 6, 2012, with respect to most of the proposed rules, but was to have ended on September 7, 2012, with respect to the proposed changes to the definition of “APR”.
On Thursday, September 6, 2012, the Board published in the Federal Register an extension of the comment period for both of the above proposed rules from September 7, 2012, to November 6, 2012. You should consult with the above publications for information on submitting comments on each of these proposed rules.