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The interpretive rule explains that because an heir has already acquired the title to the home, adding the heir as a borrower on the mortgage does not trigger the Ability-to-Repay requirements. The rule does not require the creditor to determine the heir’s ability to repay the mortgage before formally recognizing the heir as the borrower. As the named borrower, the heir may more easily be able to obtain account information, pay off the loan, or seek a loan modification.
The interpretive rule can also apply to other transfers, including transfers to living trusts, transfers during life from parents to children, transfers resulting from divorce or legal separation, and other family-related transfers.
UNCLAIMED PROPERTY HANDBOOK
updated 04/26/16 07:15 AM
Plus, Title XIV Mortgage Updates
California State Controller's Office has issued an updated Unclaimed Property Holder Handbook with changes to reflect:
CREDIT CARD SUBMISSION GUIDANCE
updated 04/18/16 12:02 PM
Plus, Compliance Advice Webinar
The Consumer Financial Protection Bureau (CFPB) has issued guidance for credit card issuers with simplified instructions for making the required submissions under Regulation Z. Last year, the CFPB temporarily suspended this rule until April 30, 2016. Issuers have to submit credit card agreements to the Bureau by May 2, 2016, and quarterly thereafter.