source:
  type: regulation
  id: reg-z-1026-supplement-i-nontrid
  authority: "Supplement I to 12 CFR Part 1026 \u2014 Official Bureau Interpretations (Regulation Z Commentary, Non-TRID Sections)"
  description: "Supplement I to 12 CFR Part 1026 is the CFPB's official staff\ncommentary on Regulation Z. This register captures the\noperationally-load-bearing\
    \ commentary interpreting the non-TRID\nsections only: \xA71026.20 (post-consummation events), \xA71026.23\n(rescission), \xA71026.32 (high-cost\
    \ mortgages), \xA71026.34 (HOEPA\nprohibited acts), \xA71026.35 (HPMLs), \xA71026.36 (LO compensation /\nservicing / arbitration), and \xA7\
    1026.43 (ATR/QM). TRID sections\n(\xA7\xA71026.18, .19(e)/(f)/(g), .37, .38) are covered separately in\nreg-z-1026-supplement-i-trid. Each\
    \ obligation cites the verbatim\ncomment text and identifies the parent rule it interprets via the\n`interprets` field.\n"
obligations:
- id: reg-z-1026-supp-i-20a-refinancing-definition
  canonical_id: reg-z-1026-supp-i-20a-refinancing-definition
  section: "Supplement I \u2014 Comment 20(a)-1: \xA71026.20(a) refinancing definition"
  description: "The Bureau interprets \xA71026.20(a) such that a \"refinancing\" is a\nnew transaction requiring a complete new set of disclosures.\n\
    Whether a refinancing has occurred is determined by whether the\noriginal obligation has been satisfied or extinguished and\nreplaced by a\
    \ new obligation, based on the parties' contract\nand applicable law. Mere changes in the terms of an existing\nobligation (e.g., deferral\
    \ of installments) do not constitute a\nrefinancing unless accomplished by cancellation of the original\nand substitution of a new obligation.\n"
  interprets: reg-z-1026.20-a-refinancing-new-disclosures
  type: do
  audit_question: "Does [LENDER]'s post-consummation modification workflow distinguish (a) modifications that merely change terms of the existing\
    \ obligation (no new \xA71026.18 disclosures required) from (b) transactions that satisfy/extinguish the original and substitute a new obligation\
    \ (refinancings requiring new disclosures), per Comment 20(a)-1?"
  workflow_phase: servicing
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - refinancing
  - servicing
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 20(a)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: 1. Definition. A refinancing is a new transaction requiring a complete new set of disclosures. Whether a refinancing has
      occurred is determined by reference to whether the original obligation has been satisfied or extinguished and replaced by a new obligation,
      based on the parties' contract and applicable law.
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the headline portion of Comment

      20(a)-1; the i. (deferral does not count) and ii. (substitution

      counts even if no substantive change) clauses are paraphrased

      in description.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Does the overall program account for the refinancing/modification distinction \u2014 so the post-consummation workflow treats\
    \ a transaction that satisfies/extinguishes the original and substitutes a new obligation as a refinancing requiring complete new \xA71026.18\
    \ disclosures, while a mere change in terms of the existing obligation triggers none?"
  file_review: 'Spot-check exemplar post-consummation modification files: confirm those that merely deferred installments / changed terms got
    no new disclosures, and those that cancelled-and-substituted a new obligation got the full new disclosure set.'
  judgment: false
- id: reg-z-1026-supp-i-20c-arm-loan-modification-exclusion
  canonical_id: reg-z-1026-supp-i-20c-arm-loan-modification-exclusion
  section: "Supplement I \u2014 Comment 20(c)-2: \xA71026.20(c) ARM rate-adjustment notice \u2014 loss-mitigation-mod exclusion"
  description: "The Bureau interprets \xA71026.20(c) such that the interest-rate-\nadjustment disclosures are required only for interest-rate\n\
    adjustments occurring pursuant to the loan contract. Creditors,\nassignees, and servicers need not provide the \xA71026.20(c)\ndisclosures\
    \ for interest-rate adjustments occurring in loan\nmodifications made for loss-mitigation purposes. Subsequent\ninterest-rate adjustments\
    \ resulting in a corresponding payment\nchange occurring pursuant to the modified loan contract,\nhowever, are subject to \xA71026.20(c).\n"
  interprets: reg-z-1026.20-c-arm-rate-adjustment-notice
  type: monitor
  audit_question: "For every ARM rate adjustment [LENDER] (as creditor, assignee, or servicer) sends a \xA71026.20(c) notice for, does [LENDER]'s\
    \ notice logic (i) suppress the notice for an adjustment made under a loss-mitigation modification, AND (ii) resume sending the notice for\
    \ subsequent adjustments under the modified loan contract, per Comment 20(c)-2?"
  workflow_phase: servicing
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - arm
  - loss-mitigation
  - servicing
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 20(c)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: "2. Loan modifications. Under \xA7 1026.20(c) , the interest rate adjustment disclosures are required only for interest rate\
      \ adjustments occurring pursuant to the loan contract. Accordingly, creditors, assignees, and servicers need not provide the disclosures\
      \ for interest rate adjustments occurring in loan modifications made for loss mitigation purposes. Subsequent interest rate adjustments\
      \ resulting in a corresponding payment change occurring pursuant to the modified loan contract, however, are subject to the requirements\
      \ of \xA7 1026.20(c) ."
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the full Comment 20(c)-2 text.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Does the overall program account for the loss-mitigation-modification exclusion \u2014 suppressing the \xA71026.20(c) ARM rate-adjustment\
    \ notice for an adjustment made under a loss-mit modification, while resuming the notice for subsequent adjustments occurring under the modified\
    \ loan contract?"
  file_review: 'Spot-check exemplar loss-mit-modified ARM files: confirm the notice was suppressed for the modification adjustment and resumed
    for later contract-driven adjustments.'
  judgment: false
- id: reg-z-1026-supp-i-23a3-rescission-period-three-events
  canonical_id: reg-z-1026-supp-i-23a3-rescission-period-three-events
  section: "Supplement I \u2014 Comment 23(a)(3)-1: \xA71026.23(a)(3) rescission period runs from last of 3 events"
  description: "The Bureau interprets \xA71026.23(a)(3) such that the period\nwithin which the consumer may exercise the right to rescind\nruns\
    \ for 3 business days from the LAST of three events:\n(A) consummation of the transaction, (B) delivery of all\nmaterial disclosures, and\
    \ (C) delivery to the consumer of the\nrequired rescission notice. The 3-business-day clock does not\nstart until ALL THREE have occurred.\n"
  interprets: reg-z-1026.23-a3-rescission-window-midnight-third-day
  type: do
  audit_question: "For every rescindable transaction [LENDER] originates, does [LENDER]'s rescission-window calculation start the 3-business-day\
    \ clock only from the LATEST of (A) consummation, (B) delivery of all material disclosures, and (C) delivery of the \xA71026.23(b) rescission\
    \ notice, per Comment 23(a)(3)-1?"
  workflow_phase: closing
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - rescission
  - 3-day
  - closing
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 23(a)(3)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: '1. Rescission period. i. The period within which the consumer may exercise the right to rescind runs for 3 business days
      from the last of 3 events:'
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the Comment 23(a)(3)-1 headline

      operative sentence; the A/B/C event enumeration is paraphrased

      in description.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Do the P&Ps ensure the rescission-window calculation starts the 3-business-day clock only from the LATEST of (A) consummation,\
    \ (B) delivery of all material disclosures, and (C) delivery of the \xA71026.23(b) rescission notice \u2014 never starting before all three\
    \ have occurred?"
  file_review: Pull rescindable-transaction files; confirm the documented window start equals the latest of the three events, not consummation
    alone.
  judgment: false
  feeds:
  - reg-z-1026-supp-i-23c-no-disbursement-during-delay
- id: reg-z-1026-supp-i-23b1-two-copies-to-each-consumer
  canonical_id: reg-z-1026-supp-i-23b1-two-copies-to-each-consumer
  section: "Supplement I \u2014 Comment 23(b)(1)-1: \xA71026.23(b)(1) two copies of rescission notice per consumer"
  description: "The Bureau interprets \xA71026.23(b)(1) such that each consumer\nentitled to rescind must be given TWO copies of the rescission\n\
    notice and ONE copy of the material disclosures. In a\ntransaction involving joint owners both of whom are entitled to\nrescind, each must\
    \ receive two copies of the rescission notice\n(one copy to each if provided in electronic form in accordance\nwith E-Sign Act provisions).\n"
  interprets: reg-z-1026.23-b1-notice-of-right-to-rescind
  type: do
  audit_question: "For every rescindable transaction [LENDER] originates with multiple owners entitled to rescind, does [LENDER]'s closing process\
    \ deliver TWO copies of the \xA71026.23(b) rescission notice to EACH such consumer (and one copy of material disclosures to each), per Comment\
    \ 23(b)(1)-1?"
  workflow_phase: closing
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - rescission
  - notice-delivery
  - closing
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 23(b)(1)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: 1. Who receives notice. Each consumer entitled to rescind must be given two copies of the rescission notice and the material
      disclosures.
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the headline portion of Comment

      23(b)(1)-1; the joint-owner detail is paraphrased in

      description.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Does the closing process ensure each consumer entitled to rescind receives TWO copies of the rescission notice (one each if\
    \ E-Sign-compliant electronic) and one copy of the material disclosures \u2014 including each joint owner in a multiple-owner transaction?"
  file_review: Pull multi-owner rescindable files; confirm two rescission-notice copies per entitled consumer and one material-disclosures copy
    each.
  judgment: false
- id: reg-z-1026-supp-i-23c-no-disbursement-during-delay
  canonical_id: reg-z-1026-supp-i-23c-no-disbursement-during-delay
  section: "Supplement I \u2014 Comment 23(c)-1: \xA71026.23(c) no creditor performance during rescission window"
  description: "The Bureau interprets \xA71026.23(c) such that until the\nrescission period has expired and [LENDER] is reasonably\nsatisfied\
    \ that the consumer has not rescinded, [LENDER] must\nnot, either directly or through a third party: (i) disburse\nloan proceeds to the consumer,\
    \ (ii) begin performing services\nfor the consumer, or (iii) deliver materials to the consumer.\nA valid escrow arrangement may hold proceeds\
    \ during the\nrescission period.\n"
  interprets: reg-z-1026.23-c-delay-of-creditor-performance
  type: dont
  audit_question: "For every rescindable transaction [LENDER] originates, does [LENDER]'s closing-and-funding workflow prohibit loan-proceed disbursement,\
    \ service performance, and materials delivery until (i) the \xA71026.23(a)(3) rescission window has expired AND (ii) [LENDER] is reasonably\
    \ satisfied (via mail-delay wait or written non-rescission statement) that no consumer entitled to rescind has done so, per Comment 23(c)-1?"
  workflow_phase: closing
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - rescission
  - funding
  - closing
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 23(c)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: '1. General rule. Until the rescission period has expired and the creditor is reasonably satisfied that the consumer has
      not rescinded, the creditor must not, either directly or through a third party:'
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the Comment 23(c)-1 headline

      operative sentence; the (i)/(ii)/(iii) prohibited acts and the

      escrow exception are paraphrased in description.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Does the closing-and-funding workflow prohibit disbursing loan proceeds, performing services, or delivering materials (directly\
    \ or through a third party) until the rescission window has expired AND the creditor is reasonably satisfied no entitled consumer rescinded\
    \ \u2014 permitting only a valid escrow hold during the window?"
  file_review: Pull funded rescindable files; confirm no disbursement/performance/delivery occurred before window expiry plus the reasonable-satisfaction
    step (mail-delay wait or written non-rescission statement).
  judgment: false
- id: reg-z-1026-supp-i-23d2-refunds-include-broker-fees
  canonical_id: reg-z-1026-supp-i-23d2-refunds-include-broker-fees
  section: "Supplement I \u2014 Comment 23(d)(2)-1: \xA71026.23(d)(2) refunds include any amount paid by consumer"
  description: "The Bureau interprets \xA71026.23(d)(2) such that, upon\nrescission, the consumer cannot be required to pay any amount\nin the\
    \ form of money or property either to [LENDER] or to a\nthird party as part of the credit transaction. Any amounts of\nthis nature already\
    \ paid by the consumer must be refunded.\n\"Any amount\" includes finance charges already accrued, broker\nfees, application and commitment\
    \ fees, fees for title search\nor appraisal \u2014 whether paid to [LENDER], directly to a third\nparty, or passed through [LENDER] to the\
    \ third party. It is\nirrelevant that these amounts may not represent profit to\n[LENDER].\n"
  interprets: reg-z-1026.23-c-delay-of-creditor-performance
  type: do
  audit_question: "When a consumer exercises the \xA71026.23 right of rescission, does [LENDER]'s refund process (within the \xA71026.23(d)(2)\
    \ 20-day window) include refund of broker fees, application fees, commitment fees, title-search fees, appraisal fees, and any accrued finance\
    \ charges \u2014 whether paid to [LENDER] or through [LENDER] to a third party, per Comment 23(d)(2)-1?"
  workflow_phase: closing
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: per-rescission
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - rescission
  - refund
  - closing
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 23(d)(2)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: 1. Refunds to consumer. The consumer cannot be required to pay any amount in the form of money or property either to the
      creditor or to a third party as part of the credit transaction. Any amounts of this nature already paid by the consumer must be refunded.
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the Comment 23(d)(2)-1

      operative refund-of-any-amount rule; the broker/application/

      title/appraisal enumeration is paraphrased in description.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Does the rescission-refund process, within the 20-day window, return every amount the consumer paid as money or property \u2014\
    \ accrued finance charges, broker fees, application and commitment fees, title-search and appraisal fees \u2014 whether paid to the creditor,\
    \ directly to a third party, or passed through the creditor, regardless of whether the amount was profit to the creditor?"
  file_review: Pull exercised-rescission files; confirm the refund captured each fee category (broker/application/commitment/title/appraisal/accrued
    finance charge) including pass-through-to-third-party amounts.
  judgment: false
- id: reg-z-1026-supp-i-32a1i-apor-comparable-transaction
  canonical_id: reg-z-1026-supp-i-32a1i-apor-comparable-transaction
  section: "Supplement I \u2014 Comment 32(a)(1)(i)-1: \xA71026.32(a)(1)(i) APOR coverage test"
  description: "The Bureau interprets \xA71026.32(a)(1)(i) such that high-cost\nmortgages include closed-end and open-end consumer credit\ntransactions\
    \ secured by the consumer's principal dwelling with\nan APR that exceeds the average prime offer rate for a\ncomparable transaction as of\
    \ the date the interest rate is set\nby the specified amount. \"Average prime offer rate\" is defined\nat \xA71026.35(a)(2) and published\
    \ by the Bureau in table form.\n"
  interprets: reg-z-1026.32-a1-high-cost-coverage-tests
  type: monitor
  audit_question: For every closed-end or open-end consumer credit transaction [LENDER] originates secured by the consumer's principal dwelling,
    does [LENDER]'s HOEPA-coverage test compare the transaction's APR to the APOR for a comparable transaction as of the rate-set date, using
    the Bureau's published APOR tables, per Comment 32(a)(1)(i)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - hoepa
  - apor
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 32(a)(1)(i)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: 1. Average prime offer rate. High-cost mortgages include closed- and open-end consumer credit transactions secured by the
      consumer's principal dwelling with an annual percentage rate that exceeds the average prime offer rate for a comparable transaction as of
      the date the interest rate is set by the specified amount.
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the full Comment 32(a)(1)(i)-1

      operative APOR-comparison rule.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: Does the HOEPA-coverage test compare each principal-dwelling-secured closed-end or open-end transaction's APR to the APOR for
    a comparable transaction as of the rate-set date, using the Bureau's published APOR tables?
  file_review: Pull a sample of coverage-test records; confirm the APR-vs-APOR comparison used the comparable-transaction APOR as of the rate-set
    date from the published tables.
  judgment: false
- id: reg-z-1026-supp-i-34a3-totality-of-circumstances-borrower-interest
  canonical_id: reg-z-1026-supp-i-34a3-totality-of-circumstances-borrower-interest
  section: "Supplement I \u2014 Comment 34(a)(3)-1: \xA71026.34(a)(3) borrower-interest test for HOEPA refi within one year"
  description: "The Bureau interprets \xA71026.34(a)(3) such that the\ndetermination of whether a HOEPA-to-HOEPA refinancing within\none year\
    \ is in the borrower's interest is based on the totality\nof the circumstances, at the time the credit is extended. A\nwritten statement by\
    \ the borrower that \"this loan is in my\ninterest\" alone does NOT meet this standard. A refinancing\nwould be in the borrower's interest\
    \ if needed to meet the\nborrower's bona fide personal financial emergency; for refis\nproviding additional funds, consideration should be\
    \ given to\nwhether loan fees are commensurate with the new funds advanced\nand whether real-estate charges are bona fide and reasonable.\n"
  interprets: reg-z-1026.34-a3-refinance-within-one-year-prohibition
  type: do
  audit_question: For every HOEPA-to-HOEPA refinancing [LENDER] originates within one year of the prior HOEPA loan, does [LENDER]'s file include
    a totality-of-circumstances borrower-interest analysis (not merely a borrower statement) covering bona-fide-emergency rationale or fee-commensurateness
    for new funds advanced, per Comment 34(a)(3)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - hoepa
  - refinancing
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 34(a)(3)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: "1. In the borrower's interest. The determination of whether or not a refinancing covered by \xA7 1026.34(a)(3) is in the\
      \ borrower's interest is based on the totality of the circumstances, at the time the credit is extended. A written statement by the borrower\
      \ that \u201Cthis loan is in my interest\u201D alone does not meet this standard."
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the Comment 34(a)(3)-1

      operative totality-of-circumstances rule; the bona-fide-

      emergency and fee-commensurateness factors are paraphrased.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Do the P&Ps facilitate a totality-of-the-circumstances borrower-interest analysis (at the time credit is extended) for any\
    \ HOEPA-to-HOEPA refinancing within one year \u2014 covering bona-fide-emergency rationale or fee-commensurateness for new funds advanced\
    \ \u2014 rather than accepting a bare borrower statement that the loan is in their interest?"
  file_review: Review the whole file for any within-one-year HOEPA-to-HOEPA refi; the compliance person judges whether the documented totality
    analysis genuinely shows the refinancing was in the borrower's interest.
  judgment: true
- id: reg-z-1026-supp-i-34a5i-no-credit-before-counseling
  canonical_id: reg-z-1026-supp-i-34a5i-no-credit-before-counseling
  section: "Supplement I \u2014 Comment 34(a)(5)(i)-3: \xA71026.34(a)(5)(i) HOEPA pre-loan counseling must precede extension"
  description: "The Bureau interprets \xA71026.34(a)(5)(i) such that prior to\nreceiving certification of counseling, [LENDER] may not extend\n\
    a high-cost mortgage. [LENDER] may engage in other activities\n(such as processing an application by ordering an appraisal or\ntitle search)\
    \ prior to receiving counseling certification, but\nconsummation may not occur.\n"
  interprets: reg-z-1026.34-a5-pre-loan-counseling-required
  type: dont
  audit_question: "For every high-cost mortgage [LENDER] originates, does [LENDER]'s closing checklist confirm receipt of the \xA71026.34(a)(5)(i)\
    \ HUD-approved-counselor or State-housing-finance-authority counseling certification BEFORE consummation, per Comment 34(a)(5)(i)-3?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - hoepa
  - counseling
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 34(a)(5)(i)-3"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: 3. Processing applications. Prior to receiving certification of counseling, a creditor may not extend a high-cost mortgage,
      but may engage in other activities, such as processing an application that will result in the extension of a high-cost mortgage (by, for
      example, ordering an appraisal or title search).
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the full Comment 34(a)(5)(i)-3

      operative no-extension-before-counseling rule.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Does the closing checklist block consummation of any high-cost mortgage until the \xA71026.34(a)(5)(i) counseling certification\
    \ is received (while permitting pre-counseling processing activities like ordering an appraisal or title search)?"
  file_review: Pull high-cost-mortgage files; confirm the counseling certification predates consummation.
  judgment: false
- id: reg-z-1026-supp-i-35b1-escrow-pre-consummation
  canonical_id: reg-z-1026-supp-i-35b1-escrow-pre-consummation
  section: "Supplement I \u2014 Comment 35(b)(1)-1: \xA71026.35(b)(1) escrow account must be established before consummation"
  description: "The Bureau interprets \xA71026.35(b)(1) such that [LENDER] must\nestablish an escrow account for payment of property taxes and\n\
    premiums for mortgage-related insurance required by [LENDER]\nBEFORE the consummation of a higher-priced mortgage loan\nsecured by a first\
    \ lien on a principal dwelling. Section 6 of\nRESPA (12 U.S.C. \xA72605) and Regulation X (12 CFR \xA71024.17)\naddress how the escrow account\
    \ must be administered.\n"
  interprets: reg-z-1026.35-b1-escrow-first-lien-hpml
  type: do
  audit_question: "For every first-lien HPML [LENDER] originates secured by a principal dwelling, does [LENDER]'s closing process establish the\
    \ \xA71026.35(b)(1) escrow account for taxes and required mortgage-related insurance BEFORE consummation (and administer it per Reg X \xA7\
    1024.17), per Comment 35(b)(1)-1?"
  workflow_phase: closing
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - hpml
  - escrow
  - closing
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 35(b)(1)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: 1. Administration of escrow accounts. Section 1026.35(b)(1) requires creditors to establish an escrow account for payment
      of property taxes and premiums for mortgage-related insurance required by the creditor before the consummation of a higher-priced mortgage
      loan secured by a first lien on a principal dwelling.
    drafter_attestation: "Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at\n2026-05-22T19:30Z. Substring is the headline portion\
      \ of Comment\n35(b)(1)-1; the cross-reference to RESPA \xA76 and Reg X \xA71024.17\nis paraphrased in description.\n"
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Does the closing process establish the escrow account for property taxes and required mortgage-related insurance BEFORE consummation\
    \ of every first-lien HPML secured by a principal dwelling, and administer it per RESPA \xA76 / Reg X \xA71024.17?"
  file_review: Pull first-lien HPML files; confirm escrow establishment predates consummation.
  judgment: false
- id: reg-z-1026-supp-i-35a1-comparable-apor-table
  canonical_id: reg-z-1026-supp-i-35a1-comparable-apor-table
  section: "Supplement I \u2014 Comment 35(a)(1)-1: \xA71026.35(a)(1) comparable transaction for APOR comparison"
  description: "The Bureau interprets \xA71026.35(a)(1) such that a higher-priced\nmortgage loan is a consumer credit transaction secured by the\n\
    consumer's principal dwelling with an APR that exceeds the\naverage prime offer rate for a comparable transaction as of the\ndate the interest\
    \ rate is set by the specified margin. The\ntable of average prime offer rates published by the Bureau\nindicates how to identify the comparable\
    \ transaction.\n"
  interprets: reg-z-1026.35-b1-escrow-first-lien-hpml
  type: monitor
  audit_question: For every closed-end consumer credit transaction secured by the borrower's principal dwelling, does [LENDER]'s HPML-coverage
    test compare the transaction's APR to the APOR for the comparable transaction (as identified by the Bureau's published APOR table) as of the
    date the interest rate is set, per Comment 35(a)(1)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - hpml
  - apor
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 35(a)(1)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: 1. Comparable transaction. A higher-priced mortgage loan is a consumer credit transaction secured by the consumer's principal
      dwelling with an annual percentage rate that exceeds the average prime offer rate for a comparable transaction as of the date the interest
      rate is set by the specified margin.
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the headline portion of Comment

      35(a)(1)-1; the published-APOR-table reference is paraphrased.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: Does the HPML-coverage test compare each principal-dwelling-secured closed-end transaction's APR to the APOR for the comparable
    transaction (as identified by the Bureau's published APOR table) as of the date the interest rate is set?
  file_review: Pull a sample of HPML coverage-test records; confirm the comparable-transaction APOR and rate-set date were used per the published
    table.
  judgment: false
- id: reg-z-1026-supp-i-36d1-objective-facts-based-on-term
  canonical_id: reg-z-1026-supp-i-36d1-objective-facts-based-on-term
  section: "Supplement I \u2014 Comment 36(d)(1)-1.i: \xA71026.36(d)(1) \"based on\" a term means objective facts and circumstances"
  description: "The Bureau interprets \xA71026.36(d)(1) such that whether\ncompensation is \"based on\" a term of a transaction does NOT\nrequire\
    \ a comparison of multiple transactions or proof of\nsubjective intent. Instead, the determination is based on the\nobjective facts and circumstances\
    \ indicating that compensation\nwould have been different if a transaction term had been\ndifferent. Generally, when a compensation policy\
    \ is in place\nand was followed, the determination is made by analyzing the\npolicy. Absent a policy (or when not followed), the\ndetermination\
    \ may be made by comparing transactions originated\nand the amounts of compensation paid.\n"
  interprets: reg-z-1026.36-d1-prohibited-comp-based-on-term
  type: monitor
  audit_question: "Does [LENDER]'s LO-compensation policy (and actual compensation paid per the policy) survive Comment 36(d)(1)-1.i objective-facts\
    \ analysis \u2014 i.e., would the same comp have been paid regardless of any transaction term (rate, points, LTV, loan amount tiers used as\
    \ proxy, etc.)?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - lo-compensation
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 36(d)(1)-1.i"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: "1. Compensation that is \u201Cbased on\u201D a term of a transaction. i. Objective facts and circumstances. Whether compensation\
      \ is \u201Cbased on\u201D a term of a transaction does not require a comparison of multiple transactions or proof that any person subjectively\
      \ intended that there be a relationship between the amount of the compensation paid and a transaction term."
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the headline portion of Comment

      36(d)(1)-1.i; the policy-analysis and comparison-of-transactions

      methods are paraphrased in description.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Do the P&Ps ensure the LO-compensation policy can survive the objective-facts-and-circumstances test \u2014 i.e., the policy,\
    \ as written and as actually followed, would pay the same compensation regardless of any transaction term (no subjective-intent or multi-transaction-comparison\
    \ defense needed)?"
  file_review: Analyze the comp policy and the compensation actually paid; the compliance person judges whether comp would have differed had a
    transaction term differed (analyze the policy where one exists and was followed; compare transactions and amounts paid where there is no policy
    or it was not followed).
  judgment: true
- id: reg-z-1026-supp-i-36d1-proxy-for-term
  canonical_id: reg-z-1026-supp-i-36d1-proxy-for-term
  section: "Supplement I \u2014 Comment 36(d)(1)-2.ii: \xA71026.36(d)(1) proxy-for-a-term test"
  description: "The Bureau interprets \xA71026.36(d)(1) such that, even if a\nfactor is not itself a term of a transaction, it is a \"proxy\"\n\
    for a term if (i) the factor consistently varies with a term\nor terms of the transaction over a significant number of\ntransactions, AND\
    \ (ii) the loan originator has the ability,\ndirectly or indirectly, to add, drop, or change the factor\nwhen originating the transaction.\
    \ Example: paying higher\ncommission for loans held in portfolio vs. sold to secondary\nmarket \u2014 if portfolio loans consistently have\
    \ different\ninterest rates / terms and the LO can advise the consumer\ntoward a portfolio loan, \"held in portfolio\" is a proxy for\ninterest\
    \ rate or term.\n"
  interprets: reg-z-1026.36-d1-prohibited-comp-based-on-term
  type: monitor
  audit_question: For each non-transaction-term factor [LENDER] uses to determine LO compensation (e.g., product type, channel, geography, hold-vs-sell,
    customer tenure), does [LENDER] perform an empirical proxy test (Comment 36(d)(1)-2.ii) confirming the factor does NOT consistently vary with
    a transaction term over a significant number of transactions where the LO has discretion to change it?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: continuous
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - lo-compensation
  - proxy
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 36(d)(1)-2.ii"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: ii. Proxies for terms of a transaction. If the loan originator's compensation is based in whole or in part on a factor that
      is a proxy for a term of a transaction, then the loan originator's compensation is based on a term of a transaction. A factor (that is not
      itself a term of a transaction) is a proxy for a term of a transaction if the factor consistently varies with a term or terms of the transaction
      over a significant number of transactions, and the loan originator has the ability, directly or indirectly, to add, drop, or change the
      factor when originating the transaction.
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the full Comment 36(d)(1)-2.ii

      operative two-prong proxy test (less the portfolio-vs-secondary

      example, which is paraphrased in description).

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Do the P&Ps require an empirical proxy test for each non-transaction-term factor used to set LO compensation \u2014 confirming\
    \ the factor does NOT both (i) consistently vary with a transaction term over a significant number of transactions AND (ii) lie within the\
    \ LO's ability to add, drop, or change when originating?"
  file_review: Review the proxy analysis for each comp factor; the compliance person judges whether the factor consistently varies with a term
    over a significant number of transactions where the LO has discretion to change it.
  judgment: true
- id: reg-z-1026-supp-i-36e1-steering-in-consumer-interest
  canonical_id: reg-z-1026-supp-i-36e1-steering-in-consumer-interest
  section: "Supplement I \u2014 Comment 36(e)(1)-2: \xA71026.36(e)(1) prohibited steering \u2014 comp-driven choice not in consumer interest"
  description: "The Bureau interprets \xA71026.36(e)(1) such that a loan\noriginator may not direct or steer a consumer to consummate a\ntransaction\
    \ based on the fact that the loan originator would\nincrease the amount of compensation that the LO would receive\nfor that transaction compared\
    \ to other transactions, UNLESS\nthe consummated transaction is in the consumer's interest. The\ntransaction must be compared to other possible\
    \ loan offers\navailable through the LO for which the consumer was likely to\nqualify at the time the transaction was offered.\n"
  interprets: reg-z-1026.36-e1-prohibited-steering
  type: dont
  audit_question: For every transaction where [LENDER]'s LO directed the consumer toward a higher-LO-compensation option among possible loan offers
    the consumer likely qualified for, can [LENDER] evidence the consummated transaction was in the consumer's interest under Comment 36(e)(1)-2
    (e.g., the lower-comp alternative had a prepayment penalty, higher up-front costs the consumer could not pay, etc.)?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - steering
  - lo-compensation
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 36(e)(1)-2"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: "2. Prohibited conduct. Under \xA7 1026.36(e)(1) , a loan originator may not direct or steer a consumer to consummate a transaction\
      \ based on the fact that the loan originator would increase the amount of compensation that the loan originator would receive for that transaction\
      \ compared to other transactions, unless the consummated transaction is in the consumer's interest."
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the full Comment 36(e)(1)-2

      operative prohibited-conduct rule; the "compared to other

      possible loan offers available through the originator" detail

      is paraphrased in description.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: Do the P&Ps facilitate evidencing, whenever an LO directed a consumer toward a higher-LO-comp option among offers the consumer
    likely qualified for, that the consummated transaction was nonetheless in the consumer's interest (compared against the other available offers
    at the time)?
  file_review: Review the whole file for any higher-comp-directed transaction; the compliance person judges whether the consummated transaction
    was genuinely in the consumer's interest versus the lower-comp alternatives the consumer likely qualified for.
  judgment: true
- id: reg-z-1026-supp-i-36e3-three-creditor-significance
  canonical_id: reg-z-1026-supp-i-36e3-three-creditor-significance
  section: "Supplement I \u2014 Comment 36(e)(3)-1: \xA71026.36(e)(3) \"significant number of creditors\" = 3 or more"
  description: "The Bureau interprets \xA71026.36(e)(3) such that a \"significant\nnumber of the creditors with which a loan originator regularly\n\
    does business\" is THREE OR MORE of those creditors. If the LO\nregularly does business with fewer than three creditors, the\nLO is deemed\
    \ to comply by obtaining loan options from all the\ncreditors with which it regularly does business. The LO must\nOBTAIN options from a significant\
    \ number, but need not PRESENT\noptions from all such creditors.\n"
  interprets: reg-z-1026.36-e1-prohibited-steering
  type: do
  audit_question: "For every transaction where [LENDER]'s LO seeks the \xA71026.36(e)(2) safe-harbor by presenting Comment 36(e)(3)(i) loan options,\
    \ has the LO obtained loan options from a significant number of creditors with which the LO regularly does business (three or more, or all\
    \ such creditors if fewer than three)?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - steering
  - safe-harbor
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 36(e)(3)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: 1. Significant number of creditors. A significant number of the creditors with which a loan originator regularly does business
      is three or more of those creditors.
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the headline portion of Comment

      36(e)(3)-1; the fewer-than-three default and the obtain-vs-

      present distinction are paraphrased in description.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Do the P&Ps ensure that, when an LO seeks the \xA71026.36(e)(2) steering safe-harbor, the LO obtains loan options from a significant\
    \ number of creditors it regularly does business with \u2014 three or more, or all such creditors if the LO regularly deals with fewer than\
    \ three (obtain from a significant number, though not present all)?"
  file_review: Pull safe-harbor-relied-on transactions; confirm options were obtained from three or more regularly-used creditors (or all, where
    fewer than three).
  judgment: false
- id: reg-z-1026-supp-i-36g-nmlsr-id-on-loan-documents
  canonical_id: reg-z-1026-supp-i-36g-nmlsr-id-on-loan-documents
  section: "Supplement I \u2014 Comment 36(g)-1: \xA71026.36(g) NMLSR ID required on loan documents"
  description: "The Bureau interprets \xA71026.36(g) such that a loan originator\norganization must include its name and NMLSR ID and the name\n\
    and NMLSR ID of the individual loan originator on certain loan\ndocuments. The term \"loan originator\" includes creditors that\nengage in\
    \ loan-originator activities. The NMLSR ID is generally\na number assigned by the NMLSR to individuals registered or\nlicensed through NMLSR\
    \ to provide loan-origination services.\n"
  interprets: reg-z-1026.36-g-name-nmlsr-id-on-loan-docs
  type: do
  audit_question: For every covered closed-end consumer-credit loan document [LENDER] originates (credit application, note, security instrument,
    integrated disclosures), do the documents display both the LO organization's name and NMLSR ID AND the individual LO's name and NMLSR ID,
    per Comment 36(g)-1?
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - nmlsr
  - loan-documents
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 36(g)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: 1. NMLSR ID. Section 1026.36(g) requires a loan originator organization to include its name and NMLSR ID and the name and
      NMLSR ID of the individual loan originator on certain loan documents.
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the headline portion of Comment

      36(g)-1; the creditor-included-in-LO scope detail and the

      NMLSR-ID definitional cross-reference are paraphrased in

      description.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: Do the document templates ensure every covered closed-end loan document (credit application, note, security instrument, integrated
    disclosures) displays the LO organization's name + NMLSR ID and the individual LO's name + NMLSR ID?
  file_review: Pull loan documents; confirm both organization and individual LO name + NMLSR ID appear on each required document.
  judgment: false
- id: reg-z-1026-supp-i-36i-no-financing-credit-insurance
  canonical_id: reg-z-1026-supp-i-36i-no-financing-credit-insurance
  section: "Supplement I \u2014 Comment 36(i)-1: \xA71026.36(i) financing credit insurance premiums = adding to amount owed"
  description: "The Bureau interprets \xA71026.36(i) such that, in the case of\nsingle-premium credit insurance, [LENDER] violates \xA71026.36(i)\n\
    by adding the credit-insurance premium or fee to the amount\nowed by the consumer at closing. In the case of monthly-pay\ncredit insurance,\
    \ [LENDER] violates \xA71026.36(i) if, upon the\nclose of the monthly period in which the premium or fee is\ndue, [LENDER] includes the premium\
    \ or fee in the amount owed\nby the consumer.\n"
  interprets: reg-z-1026.36-h-no-mandatory-arbitration
  type: dont
  audit_question: For every dwelling-secured closed-end consumer credit transaction [LENDER] originates, does [LENDER]'s closing process confirm
    that any single-premium credit insurance premium is NOT added to the amount owed at closing, and that any monthly-pay credit insurance premium
    is NOT added to the amount owed at any monthly close, per Comment 36(i)-1?
  workflow_phase: closing
  owner_role: compliance_officer
  secondary_owner_role: loan_officer
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - credit-insurance
  - financing-prohibition
  - closing
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 36(i)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: "1. Financing credit insurance premiums or fees. In the case of single-premium credit insurance, a creditor violates \xA7\
      \ 1026.36(i) by adding the credit insurance premium or fee to the amount owed by the consumer at closing. In the case of monthly-pay credit\
      \ insurance, a creditor violates \xA7 1026.36(i) if, upon the close of the monthly period in which the premium or fee is due, the creditor\
      \ includes the premium or fee in the amount owed by the consumer."
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the full Comment 36(i)-1

      operative financing-credit-insurance prohibition.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: Does the closing process confirm that no single-premium credit-insurance premium/fee is added to the amount owed at closing,
    and that no monthly-pay credit-insurance premium/fee is added to the amount owed at the close of the monthly period in which it is due, on
    any dwelling-secured closed-end transaction?
  file_review: Pull files with credit insurance; confirm single-premium amounts were not added to the closing balance and monthly-pay amounts
    were not rolled into the amount owed.
  judgment: false
- id: reg-z-1026-supp-i-43c1-good-faith-no-comprehensive-uw-standards
  canonical_id: reg-z-1026-supp-i-43c1-good-faith-no-comprehensive-uw-standards
  section: "Supplement I \u2014 Comment 43(c)(1)-1: \xA71026.43(c)(1) reasonable and good-faith ATR \u2014 no comprehensive UW standards"
  description: "The Bureau interprets \xA71026.43(c)(1) such that creditors are\ngenerally required to make reasonable and good-faith\ndeterminations\
    \ of consumers' ATR, but \xA71026.43(c) and the\naccompanying commentary do not provide COMPREHENSIVE\nunderwriting standards. So long as\
    \ creditors consider the\n\xA71026.43(c)(2) factors according to \xA71026.43(c) requirements,\ncreditors are permitted to develop their own\
    \ underwriting\nstandards and make changes over time. Whether a particular ATR\ndetermination is reasonable and in good faith depends not\
    \ only\non the underwriting standards adopted but on the facts and\ncircumstances of an individual extension and how [LENDER]'s\nstandards\
    \ were applied. A consumer's statement or attestation\nthat the consumer has the ability to repay is NOT indicative\nof whether [LENDER]'s\
    \ determination was reasonable and in good\nfaith.\n"
  interprets: reg-z-1026.43-c1-atr-general-rule
  type: monitor
  audit_question: "Does [LENDER]'s ATR underwriting documentation evidence (i) consideration of the eight \xA71026.43(c)(2) factors, (ii) application\
    \ of [LENDER]'s written underwriting standards to the specific facts and circumstances of each file, and (iii) reliance on more than a consumer\
    \ attestation of ability to repay, per Comment 43(c)(1)-1?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - atr
  - underwriting
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 43(c)(1)-1.i"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: "1. Reasonable and good faith determination. i. General. Creditors generally are required by \xA7 1026.43(c)(1) to make reasonable\
      \ and good faith determinations of consumers' ability to repay. Section 1026.43(c) and the accompanying commentary describe certain requirements\
      \ for making this ability-to-repay determination, but do not provide comprehensive underwriting standards to which creditors must adhere."
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the headline portion of Comment

      43(c)(1)-1.i; the "facts and circumstances" and "consumer

      attestation not indicative" rules are paraphrased in description.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Do the P&Ps require ATR documentation evidencing (i) consideration of the eight \xA71026.43(c)(2) factors, (ii) application\
    \ of the lender's own written underwriting standards to each file's specific facts and circumstances, and (iii) reliance on more than a consumer\
    \ attestation of ability to repay?"
  file_review: "Review the whole underwriting file; the compliance person judges whether the ATR determination was reasonable and in good faith\
    \ on the facts \u2014 not merely that the eight factors appear, but that the standards were soundly applied and not propped up by a borrower\
    \ attestation."
  judgment: true
- id: reg-z-1026-supp-i-43b1-covered-transaction-restates-scope
  canonical_id: reg-z-1026-supp-i-43b1-covered-transaction-restates-scope
  section: "Supplement I \u2014 Comment 43(b)(1)-1: \xA71026.43(b)(1) \"covered transaction\" restates \xA71026.43(a) scope"
  description: "The Bureau interprets \xA71026.43(b)(1) such that the definition\nof \"covered transaction\" restates the scope of the rule as\n\
    described at \xA71026.43(a). [LENDER] must apply \xA7\xA71026.43(c)\nthrough (f) (ATR/QM substantive duties) only to transactions\nthat meet\
    \ the \xA71026.43(a) covered-transaction definition\n(closed-end consumer credit secured by a dwelling, with the\nenumerated exemptions in\
    \ \xA71026.43(a)(1)-(3)).\n"
  interprets: reg-z-1026.43-a-scope-covered-transactions
  type: monitor
  audit_question: "Before applying \xA7\xA71026.43(c)-(f) ATR/QM rules, does [LENDER]'s underwriting workflow first determine whether the transaction\
    \ is a \xA71026.43(b)(1) \"covered transaction\" (i.e., not exempt under \xA71026.43(a)(1)-(3) \u2014 e.g., not an HELOC, not a temporary\
    \ bridge loan, not an HFA-program loan), per Comment 43(b)(1)-1?"
  workflow_phase: origination
  owner_role: compliance_officer
  secondary_owner_role: ''
  cadence: per-loan
  consequence: ''
  tags:
  - round-b
  - regulator-direct
  - reg-z
  - supplement-i
  - commentary
  - atr
  - qm
  - covered-transaction
  - origination
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 43(b)(1)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: "1. The definition of covered transaction restates the scope of the rule as described at \xA7 1026.43(a) ."
    drafter_attestation: 'Copied verbatim from snapshot b915082e5abf3c45 (content.txt) at

      2026-05-22T19:30Z. Substring is the full Comment 43(b)(1)-1

      operative scope-restatement.

      '
  promoted_at: '2026-05-22T19:10:07+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  program_review: "Does the overall program account for the covered-transaction gate \u2014 so the underwriting workflow first determines whether\
    \ a transaction meets the \xA71026.43(a) definition (closed-end consumer credit secured by a dwelling, not exempt under (a)(1)-(3): not a\
    \ HELOC, temporary bridge, or listed program loan) before applying the \xA7\xA71026.43(c)-(f) ATR/QM duties?"
  file_review: Spot-check exemplar files at the boundary (HELOC, bridge, HFA-program); confirm the covered-transaction determination was made
    and the ATR/QM rules applied or correctly withheld.
  judgment: false
- id: reg-z-1026-supp-i-23c-no-disbursement-during-delay-enumerated-items
  canonical_id: reg-z-1026-supp-i-23c-no-disbursement-during-delay-enumerated-items
  section: "Supplement I \u2014 Comment 23(c)-1: \xA71026.23(c) no creditor performance during rescission window \u2014 enumerated items (chapeau\
    \ recall fix)"
  description: "The enumerated provisions following the chapeau of Supplement I \u2014 Comment 23(c)-1: \xA71026.23(c) no creditor performance\
    \ during rescission window, dropped by the original extraction and restored verbatim from the snapshot."
  type: do
  tags:
  - chapeau-recall
  - regulator-direct
  - promoted
  primary_source:
    tier: 1
    authority: "Supplement I to 12 CFR Part 1026 \u2014 Comment 23(c)-1"
    source_class: cfpb-regulation
    source_url: https://www.law.cornell.edu/cfr/text/12/appendix-Supplement_I_to_part_1026
    snapshot_id: b915082e5abf3c45
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
    paragraph_quote: i. Disburse loan proceeds to the consumer. ii. Begin performing services for the consumer. iii. Deliver materials to the
      consumer.
    drafter_attestation: "Captured verbatim (whitespace-normalized) from snapshot b915082e5abf3c45 as the enumerated list immediately following\
      \ the chapeau 'ither directly or through a third party:'. List boundary captured conservatively \u2014 REVIEW the end boundary before promote."
  judgment: false
  promoted_at: '2026-06-16T19:35:54+00:00'
  promoted_from: reg-z-1026-supplement-i-nontrid-chapeau-recall-v1.yaml
  source_provenance:
    source_id: reg-z-1026-supplement-i-nontrid
    fetched_at: '2026-05-22T11:32:43Z'
    content_hash: sha256:a95287c63016b477746851f449780a22585afe510e5e03f05356aba0dd0448f1
_promotion_history:
- promoted_at: '2026-05-22T19:10:07+00:00'
  candidate_path: obligations\_remediation\_round_b_drafts\reg-z-1026-supplement-i-nontrid-roundb-v1.yaml
  candidates_promoted: 19
  candidates_skipped_existing: 0
- promoted_at: '2026-06-16T19:35:54+00:00'
  candidate_path: C:\Users\earlc\broker-tools\obligations\_remediation\chapeau-recall\reg-z-1026-supplement-i-nontrid-chapeau-recall-v1.yaml
  candidates_promoted: 1
  candidates_skipped_existing: 0
- promoted_at: '2026-06-16T19:38:25+00:00'
  candidate_path: C:\Users\earlc\broker-tools\obligations\_remediation\chapeau-recall\reg-z-1026-supplement-i-nontrid-chapeau-recall-v1.yaml
  candidates_promoted: 0
  candidates_skipped_existing: 1
- promoted_at: '2026-06-16T19:39:13+00:00'
  candidate_path: C:\Users\earlc\broker-tools\obligations\_remediation\chapeau-recall\reg-z-1026-supplement-i-nontrid-chapeau-recall-v1.yaml
  candidates_promoted: 0
  candidates_skipped_existing: 1
