The Rhode Island Department of Business Regulation (DBR) has finally adopted Regulation 3, which implements the Rhode Island Home Loan Protection Act (HLPA). There are numerous, substantive differences between the text of the emergency regulations issued on December 29, 2006 and the final version of the Regulations. To view a redlined version of Regulation 3, click here. For a description of the material, substantive changes, click here for the Concise Explanatory Statement.

Please note that as the emergency regulations will expire on April 30, 2007, the final version of Regulation 3 will become effective on May 1, 2007. However, any enforcement action related to the disclosure requirements pursuant to Regulation 3 will cover transactions initiated or pending after June 1, 2007. For more details, please view Banking Bulleting 2007-4.

As the final version of Regulation 3 was filed on April 11, 2007, DocMagic's Compliance Department has not had an opportunity to thoroughly review the adopted Regulation prior to the date of publication of the April, 2007 issue of The Compliance Wizard. To the extent that modifications will need to be made to Rhode Island's high cost test in the DocMagic software, every effort will be made to implement any modifications by the May 1, 2007 effective date. In addition, the Compliance Department will be revising the disclosures based on the adopted Regulations and will have them available on or before the June 1, 2007 enforcement date.

In the May, 2007 issue of The Compliance Wizard, the Compliance Department will provide an explanation of the impact of adopted Regulation 3 on the Rhode Island high cost test and disclosures required under the HLPA. To view the prior Compliance Wizard article regarding the disclosures required under the HLPA, please click here.

Please contact DocMagic's Compliance Department if you have any questions about the contents of this article.