TILA has been moved from the Federal Reserve to the Consumer Financial Protection Bureau. They are seeking comment on their proposed TILA, tinyurlnotallowed/9d2xy6m, rule changes. These changes would have a severe effect on owner financing.

PLEASE FOLLOW THIS LINK TO COMMENT ON THE PROPOSED TILA CHANGES: tinyurlnotallowed/8mfsbxy

CFPB's proposed changes:
* would limit seller financing transactions on dwellings to 3 per year

* The seller has to verify and document the buyer's ability to repay installment sale using the same criteria mortgage loan originators and banks are required to use. If the seller does not qualify the buyer the fines are the same as they are for MLOs and banks

* The buyer and seller are not allowed to negotiate a balloon payment. The installment sale can't negatively amortize, nor can you have an interest-only installment sale

* The installment sale has to have a fixed interest rate for the first 5 years before the interest rate can rise