A significant component of the Federal Reserve Board's new rules under TILA is the regulation of subprime loans through the addition of requirements and restrictions applicable to "higher-priced mortgage loans." Most of the new rules for higher-priced mortgage loans become effective on Oct. 1. 2009. With a comment deadline of Aug. 29, a final HMDA rule likely will not be issued until at least the end of September 2008. While this would provide lenders with little time to implement the necessary changes, the board believes that implementation will not be a significant issue.
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