On Oct. 26, the Department of Housing and Urban Development issued its final escrow accounting rule. Promulgated pursuant to the Real Estate Settlement Procedures Act, the rule was intended to provide "clear and specific" guidelines on escrow accounting procedures. It also, however, imposes daunting burdens on those rushing to meet its April 24 compliance deadline.
In the meantime, the Federal Reserve Board has proposed a Truth-in- Lending Commentary update designed partly to address the aftermath of the 11th Circuit's decision in Rodash v. AIB Mortgage Co. The proposal falls purposely short, however, of absolving lenders of all post-Rodash exposure and raises almost as many issues as it resolves.