The final mortgage rules adopted since November 2012 including the rulemaking on the TILA/RESPA disclosures, rules on Ability to Repay, Qualified Mortgages, Servicing Rules, Appraisals, Higher Risk Mortgages, Loan Originator Compensation and Qualifications were all adopted and signed by Cordray in his capacity as director and another rule on servicing transfers is expected.  Should his appointment be invalidated, Andreano said, it looks like these rules would be in a bit of trouble.  It appears Treasury would have authority to step and use its 1066 authority to validate the enumerated authority laws but not the rules signed off by Cordray.

Given that nearly all of that rule-making goes into effect in January 2014 and there is much work to be done, the general recommendation for businesses is to assume these rules will go into effect as scheduled.  Industry is looking at the situation but deciding they have no choice but to spend the billions of dollars needed to comply while moving ahead as though nothing has happened.

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