AN OVERVIEW OF THE CFPB’S HIGHER-PRICED MORTGAGE LOAN ESCROW RULE
Kristina A. Del Vecchio
Kristina A. Del Vecchio Kristina A. Del Vecchio is Of Counsel at Joseph & Cohen, P.C., where she focuses on representing and advising banks, credit unions and other financial services companies in regulatory, compliance and litigation matters. She currently is Vice Chair, Communications of the Consumer Financial Services Committee. She is a graduate of the University of Connecticut School of Law, and earned her Master of Science degree, with merit from the London School of Economics.
Since its inception, the Consumer Financial Protection Bureau ("CFPB") has issued an array of final rules affecting the United States mortgage market, pursuant to its authority under Title XIV of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").1 Among these is a rule entitled "Escrow Requirements under the Truth in Lending Act (Regulation Z)" (the "Rule"), which was issued on January 10, 2013.2 The Rule, which became effective on June 1, 2013,3 implemented statutory changes made by the Dodd-Frank Act to amend provisions of Regulation Z that require creditors to establish escrow accounts for higher-priced mortgage loans ("HPMLs") secured by a first lien on a principal dwelling.