The Latest RESPA and TILA Developments: CFPB Final Rule Changes That Are Impacting Regs X and Z, Implementation Challenges, Claims Trends and Best Practices for Compliance in Early Intervention, Loss Mitigation, Periodic Statements and Beyond
Lydia A. Morley
Vice President | Assistant General Counsel
US Bank
R. Andy Arculin
Venable LLP
Former Senior Counsel in the CFPB’s Office of Regulations
David K. Stein
Bricker & Eckler LLP
- Final amendments to RESPA servicing provisions as related to:
- Forced place insurance notices
- Policies and procedures
- Early intervention
- Loss mitigation requirements
- Final amendments to TILA servicing provisions as related to periodic statement requirements
- Assessing the implementation challenges associated with these new rules; pitfalls to avoid and best practices
- What claims trends are being seen with regard to Regs X and Z? What are these claims alleging? What are the succeeding theories of liability and succeeding defenses?
- What claims are we expecting to see on the horizon that haven’t been seen yet?
- TILA rescission post-Jesinoski – what have subsequent cases been saying about how rescission operates in practice after notice of rescission is provided?