By Kristina A. Del VecchioThe Higher-Priced Mortgage Loan Escrow Rule is among the many numerous guidelines that the Consumer Financial Protection Bureau (“CFPB”) has promulgated affecting the mortgage market. The rule grew to become effective on June 1, 2013 and applied statutory modifications made by the Dodd-Frank Act to amend provisions of Regulation Z that require collectors to determine escrow accounts for higher-priced mortgage loans . The article additionally address relevant provisions of the CFPB’s new TILA-RESPA rule, which was released on November 20, 2013. It is imperative that collectors totally understand and implement the requirements set forth by rules (along with the myriad other new mortgage-related guidelines recently promulgated by the CFPB) and work to begin implementing the related disclosure modifications set forth in the TILA-RESPA rule. In 2011, the authors first outlined the potential of using a single-member limited legal responsibility firm as a substitute for current main fashions of 501 fiscal sponsorship .
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