By Guy Puccio Business and Professions Code Section 10240(c) purportedly extends an exemption to mortgage brokers when arranging “federally regulated residential mortgage loans.” However, this exemption is inapplicable to most loan transactions conducted by mortgage brokers registered with the NMLS as an LO (MLB/MLO) and even when arranging transactions where the loan proceeds are used for personal, family, or household purposes. The phrase “federally regulated” is substantially narrower than “federally related.” Under current law, “federally regulated” loan transactions are loans made by nationally chartered or licensed banks, savings and loans, savings banks, thrifts, and credit unions; or if state chartered or licensed, those financial institutions that have...
Give Your Feedback: Dodd-Frank Combined RESPA-TILA Disclosure
This week, the Consumer Financial Protection Bureau (CFPB) released the first prototypes of a combined RESPA-TILA disclosure. Consumers and industry members are offered two different feedback paths for providing your input. Click this link to provide your comments–select the “switch to the industry tool” option at the bottom of the page: http://www.consumerfinance.gov/knowbeforeyouowe/ Thank you to our colleagues at Franzén & Salzano for the notification regarding this call-to-action.
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