Real Estate Lending A Document Compliance Overview. Judi Mortenson Lending Manager

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1 Real Estate Lending A Document Compliance Overview Judi Mortenson Lending Manager

2 Agenda Introduction Goal of todays session: Create awareness of the documents and signatures that are required for real estate secured loans based on compliance regulations. Look Back Review of Key Regulations and the Associated Docs Resources Disclosure: the information covered in this presentation is not intended to cover all regulations, and may not apply to all lenders. Consult with your legal counselor for applicability. Pg. 2

3 Looking Back 60 s and 70 s: Inflation, high rates and fees prompted consumer protection acts such as the Truth-in-Lending Act and the Real Estate Settlement Procedures Act. 80 s and 90 s: Administration push of the American Dream Technology (AU) Alternative documentation (paystubs vs VOE) 2000 s: International demand for high-yield, low risk investments fueled the market, driving innovation in lending Well, you know. And now, in the aftermath of the mortgage meltdown, we are back to where we began Pg. 3

4 Dodd-Frank Act of 2010 Among other things, Dodd-Frank: Created a new independent watch dog, housed within the Federal Reserve: Consumer Financial Protection Bureau ( CFPB ). In January, 2012, Rich Cordray was appointed the first Director of the CFPB Eliminated loop-holes that allowed risky and abusive practices Provided new rules for transparency and accountability for credit rating agencies Pg. 4

5 Consumer Financial Protection Bureau Purpose Heighten government accountability by consolidating in one place responsibilities that had been scattered across government. The consumer bureau is focused on one goal: watching out for American consumers in the market for consumer financial products and services. Supervise and enforce the laws over providers of consumer financial products and services that previously escaped regular Federal oversight. CFPB oversight is not limited to only Banks. It covers activities across many different types of financial institutions. Municipalities should check with your legal counselors to make a determination of how/if it applies to their lending activities and check with any third party administrators for compliance. Pg. 5

6 CFPB Recent Enactments of the CFPB Requires lenders to insure that borrowers have the Ability to Repay Prohibit Unfair Lending Practices: Prohibits the financial incentives for subprime loans that encourage lenders to steer borrowers into more costly loans, including the bonuses known as "yield spread premiums" that lenders pay to brokers to inflate the cost of loans. Prohibits pre-payment penalties that trapped so many borrowers into unaffordable loans. Expands Consumer Protections for High-Cost Mortgages: lowering the interest rate and the points and fee triggers that define high cost loans. Requires Additional Disclosures for Consumers on Mortgages: Lenders must disclose the maximum a consumer could pay on a variable rate mortgage, with a warning that payments will vary based on interest rate changes. Establishes an Office of Housing Counseling within HUD to boost homeownership and rental housing counseling Pg. 6

7 Key Regulations Credit Regulation B: Equal Credit Opportunity Act Regulation C: Home Mortgage Disclosure Act Information Disclosure: Regulation Z: Truth In Lending Act Regulation X: Real Estate Settlement Procedures Act Flood Disaster Protection Act Information Protection: Gramm Leach Bliley Act USA Patriot Act Pg. 7

8 Reg B: ECOA The purpose of this regulation is to promote the availability of credit to: all creditworthy applicants without regard to race, color, religion, national origin, sex, marital status, or age (provided the applicant has the capacity to contract); the fact that all or part of the applicant's income derives from a public assistance program; or the fact that the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The regulation: 1. prohibits creditor practices that discriminate on the basis of any of these factors 2. requires creditors to notify applicants of action taken on their applications 3. report credit history in the names of both spouses on an account; 4. retain records of credit applications 5. collect information about the applicant's race and other personal characteristics in applications for certain dwelling-related loans; and 6. provide applicants with copies of appraisal reports used in connection with credit transactions. Pg. 8

9 Notice of Adverse Action Key Components: Reasons for decision As many as are applicable, but not more than 4-5 Source of information Name and contact info for credit vendor if applicable Statement about the consumers rights Sent within 30-days of the decision The Notice must be sent to the Consumer to whom the credit relates and must be signed by the Company issuing the decision. Pg. 9

10 Credit Application Collect Government Monitoring ( HMDA ) information about the applicant's race and other personal characteristics in applications or other addendum forms. Collect how the application was taken. This drives what information is actually required when filing the HMDA data Applicants must attest to the type of credit they are requesting (Individual or Joint) Pg. 10

11 Notice of Right to Receive a Copy of Appraisal Credits must mail or deliver a notice in writing of the applicant s right to receive a copy of all written appraisals or valuations developed in connection with the application, no later than the third business day after the creditor receives an application for credit that is to be secured by a first lien on a dwelling. A special timing rule applies if an application for credit is not to be secured by a first lien on a dwelling at the time of application This form is not required to be signed. Then, the creditor is required to actually provide applicants with a copy of all appraisals and other written valuations promptly upon completion or at least three business days prior to loan closing. Pg. 11

12 Regulation C-HMDA This regulation is intended to provide the public with loan data that can be used: 1. To help determine whether financial institutions are serving the housing needs of their communities; 2. To assist public officials in distributing public-sector investment so as to attract private investment to areas where it is needed; and 3. To assist in identifying possible discriminatory lending patterns and enforcing antidiscrimination statutes. The regulation requires an institution to report data to its supervisory agency about home purchase loans, home improvement loans, and refinancing's that it originates or purchases, or for which it receives applications; and to disclose certain data to the public. Note: there are exemptions for some lender types, including small banks and nonprofit organizations that meet certain thresholds Neither the act nor this regulation is intended to encourage unsound lending practices or the allocation of credit. Pg. 12

13 Regulation X (1974) The Act: 1. Requires lenders, mortgage brokers, or servicers of home loans to provide borrowers with pertinent and timely disclosures regarding the nature and costs of the real estate settlement process. 2. Prohibits specific practices, such as kickbacks, and places limitations upon the use of escrow accounts. HUD originally promulgated Regulation X which implements RESPA and many changes have been made over the years. In 2008, HUD issued a RESPA Reform Rule that included substantive and technical changes to the existing RESPA regulation, that were required as of January 1, 2010 including: a standard Good Faith Estimate form a revised HUD-1 Settlement Statement In 2013 the CFPB issued final rules to further amend Regulation X including servicing provisions to the loss mitigation procedure requirements, to the requirements relating to notices of error and information requests Additionally, CFPB issued final rules for changes to the Good Faith Estimate and HUD-1 Settlement Statement (again!) that will be required use in Pg. 13

14 Regulation X Documents Good Faith Estimate HUD 1 Settlement Statement Servicing Disclosure ABA Pg. 14

15 Good Faith Estimate The Good Faith Estimate is required to be provided within 3-days of a complete application. Signatures are not required. Pg. 15

16 Servicing Disclosure When a loan will be recorded in 1 st lien position, lenders are required to disclose their intentions: will they keep it or sell it. This notice is required to be sent within 3-days of loan application. Pg. 16

17 Affiliated Business Arrangement Disclosure An Affiliated Business Arrangement (AfBA) Disclosure is required whenever a settlement service provider involved in a RESPA covered transaction refers the consumer to a provider with whom the referring party has an ownership or other beneficial interest. The disclosure must describe the business arrangement that exists between the two providers and give the borrower an estimate of the second provider's charges The referring party must give the AfBA disclosure to the consumer at or prior to the time of referral. Pg. 17

18 HUD-1 Settlement Statement This form is provided at closing and requires the signatures of all borrowers before closing (must be available 1-day prior at borrowers request) Pg. 18

19 Regulation Z: Truth-in-Lending Act (1968) Purpose: To promote the informed use of consumer credit by requiring disclosures about its terms and cost in a meaningful way so consumers can compare credit terms more readily and knowledgeably. All creditors must use the same credit terminology and expressions of rates. In addition to providing a uniform system for disclosure*, the act Protects consumers against inaccurate and unfair credit billing and credit card practices Provides consumers with rescission rights* Provides for rate caps on certain dwelling-secured loans Imposes limitations on home equity lines of credit and certain closed-end home mortgages HOEPA: Section 32 (1994) Prescribes record retention rules Provides minimum standards for most dwelling-secured loans; and Delineates and prohibits unfair or deceptive mortgage lending practices* *Indicates specific documents are required Pg. 19

20 Regulation Z Documents TIL Right of Rescission Agency Disclosure Pg. 20

21 Truth-in-Lending The information that is required to be displayed on the TIL along with the specific requirements for calculating the APR are defined the Regulation Z. This disclosure is required to be provided to the applicant within 3-days* of receipt of an application. Note: in order to complete the TIL, a GFE is necessary to determine costs/fees that are used in calculating the APR. *Days are normal business days and Government defined holidays Pg. 21

22 Agency Disclosure TILA requires lenders to disclose how they are doing business with/representing the applicant. As such, a Non-Agency Disclosure is typical. The disclosure should be provided at application or the earlier opportunity that provides the applicant with the ability to shop for the best terms. Name of Lender Pg. 22

23 Right of Rescission For transactions in which a lien will be placed on a home, except Purchase Money transactions, the borrower must be provided with 3-days* to change their mind, aka Right of Rescission. ALL persons who have an ownership interest in the property are REQUIRED to be provided with this right. The 3-days are counted in 24-hour periods, beginning the day of closing and expires on mid-night of the 3 rd day. Example: Closing is Monday. Day 1 ends Tuesday Day 2 ends Wednesday Day 3 ends Thursday at mid-night. Disbursement of loan can occur on Friday. *Days are normal business days for the lender and Government defined holidays Pg. 23

24 USA Patriot Act In 2012, the term financial institution was more broadly defined to cover additional types of companies that are required to comply with the Act. When applicable, as soon as reasonably possible, a disclosure is required notifying the consumer that identity verification is required. Pg. 24

25 Flood Disaster Protection Act The National Flood Insurance Act, several reforms, and a host of regulations guide administration of the National Flood Insurance Program. This legislation applies to property located in special flood hazard areas and is applicable for loans that are regulated by any Federal guidelines. The Act: provides federally subsidized flood insurance coverage and prohibits lenders from making or changing loans on property not covered by flood insurance. When the security property is or will be located in a special flood plain area, the lender must provide a written notice to the borrower with following information: A warning that the building or mobile home is or will be located in a flood area A description of the flood insurance purchase requirements A statement as to whether flood insurance coverage is available under the NFIP and may that it may also be available from private insurers A statement as to whether federal disaster relief assistance may be available in the event of damage to the building or mobile home caused by flooding in a federally declared disaster Sample forms are available appendix A to section of Regulation H Pg. 25

26 Gramm Leach Bliley Act GLBA requires institutions that collect and use consumer information to disclose how they use the information and what their sharing practices are. This disclosure is required when a relationship is established and annually thereafter. Also see: MN Statute 462A.065 which limits creditors use of private data on individuals. Pg. 26

27 Summary

28 Regulation Document Requirements Signature Required? Notes Reg B: ECOA Adverse Action Credit Application Appraisal Disclosure No No 1 No 1 An electronic signature can be acceptable. If an application is taken by phone, an application script that covers all pertinent disclosure information is a good business practice ; a signed copy of the disclosed information is recommended. Reg C: HMDA Credit Application or Addendum which captures Race, Sex and Ethnicity No There are provisions and instructions for applications taken by phone or electronically. Applicants are not required to provide the information even though lenders are required to report it. Reg Z: Truth In Lending Act TIL Agency Disclosure Right of Rescission Yes Yes Yes 1 1 The Right of Rescission must be signed by everyone who has an ownership interest in the property (refer to Warranty Deed) Reg X: RESPA Good Faith Estimate (GFE) HUD-1 Settlement Statement Affiliated Business Arrangement Disclosure Servicing Disclosure No Yes Yes Yes Forms are available at USA Patriot Act Information Disclosure Yes Flood Disaster Protection Act Notice No Gramm Leach Bliley Act Information Sharing Practices No Disclosure required when relationship is established and annually thereafter Mortgage The Mortgage form is not prescribed by regulation. Anyone with property ownership must sign the Mortgage. Check with the State of MN and the County the property is located in for guidance.

29 Documents Typical Early Disclosure documents (within 3-business days of receipt of an application) Required Good Faith Estimate TIL USA Patriot Act Servicing Notice Appraisal Disclosure Non-Agency Disclosure Typical Closing documents Required Note Mortgage TIL Right of Rescission Suggested Compliance Agreement Payment Instructions Pg. 29

30 Quiz! Married Applicant, with just one of the spouses on the loan application. Ok? Can you require income verification for the non-borrowing spouse? Answer: No. Regulation B: all creditworthy applicants without regard to race, color, religion, national origin, sex, marital status Who signs the Note? Who signs the Mortgage? Answer: All persons who have an ownership interest in the property: MN is an equitable property state, therefore both married persons have equal ownership and therefore both must agree to an encumbrance. Who signs the Right of Rescission? Answer: All persons who have an ownership interest in the property Who signs the other documents? Two persons apply for a loan. One is married, one is un-married. Separate applications & docs required? Answer: No. Regulatory commentary indicates that when an application is completed by two un-married individuals, there should be no expectation of confidentiality when they apply together. Who signs the Note? Who signs the Mortgage? Answer: Both borrowers plus the spouse of the married borrower. Who signs the Right of Rescission? Answer: Both borrowers plus the spouse of the married borrower. Who signs the other documents? Pg. 30

31 Where do you start? Your internal counsel Internal document and process review CFPB Checklist If you use a 3 rd party administrator, ask for a copy of their compliance manual Pg. 31

32 Resources Google (APR Calculator) Pg. 32

33 Judi Mortenson

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