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Highlight Updates Exemption authority for residential mortgage loan disclosures

The Dodd-Frank Act created an additional exemption for residential mortgage loan disclosures.229 Residential mortgage loans, discussed further in § 9.3.1, infra, are closed-end mortgages secured by a dwelling, whether or not a principal dwelling. The exemption applies both to purchase money and refinance loans. The exemption for residential mortgage loans permits the CFPB to improve consumer awareness and understanding by modifying or exempting from disclosure requirements any class of such loans if in the interest of consumers and the public.230

Relying in part on this authority,231 the CFPB granted a partial exemption from the TILA/RESPA integrated disclosures for certain mortgage loans provided through housing assistance loan programs for low- and moderate-income households.232 The characteristics of these loans are described in §, supra.233 These loans are not exempt from any other TILA requirements.234


  • 229 Pub. L. No. 111-203, 124 Stat. 1376, § 1405(b) (July 21, 2010), codified at 15 U.S.C. § 1601 note.

  • 230 Id.

  • 231 78 Fed. Reg. 79,730, 79,772–79,773 (Dec. 31, 2013) (section-by-section analysis for 12 C.F.R. § 1026.3(h)).

  • 232 Reg. Z § 1026.3(h); Official Interpretations § 1026.3(h).

  • 233 See also §, infra.

  • 234 Official Interpretations § 1026.3(h)-1.

    Moreover, the creditor must provide the disclosures required by Reg. Z § 1026.18 even if it would not otherwise be subject to the requirements of § 1026.18. Id.