2011 PUBLIC POLICY PRIORITIES

Size: px
Start display at page:

Download "2011 PUBLIC POLICY PRIORITIES"

Transcription

1 2011 PUBLIC POLICY PRIORITIES 2111 Wilson Blvd., Suite 100 Arlington, VA 22201

2 MHI s NatIONal COMMuNIty COuNCIl The MHI National Communities Council (NCC) is the only national organization representing the interests of manufactured home community owners, operators, managers, developers, lenders and suppliers. The NCC serves its members by being an effective advocate for its members and this real estate asset class before public policy makers, the media and the general public. The NCC strives to improve the business climate for its members, increase professionalism within the industry and create more opportunities for the successful development and operation of land-lease communities. Members do business with members! The NCC is a leader it impacts the legislative and regulatory issues of importance to manufactured home communities. Since its inception the NCC has left its mark on a number of important community issues, including the Housing for Older Persons Act (HOPA); occupancy standards; satellite dish and antenna regulations; EPA water monitoring and reporting requirements; bankruptcy reform; mailbox regulations; electric utility restructuring; and private property rights. The NCC serves as a clearinghouse for information of interest to manufactured home community owners, managers and service providers. This information is provided through a weekly electronic update, as well as a quarterly industry e-newsletter called Community Connections. The NCC provides networking opportunities to exchange ideas and discuss issues of importance to your business with fellow community owners, managers as well as other industry members. NCC members are encouraged to attend and participate in MHI s national business meetings as well as the National Congress & Expo, held in Las Vegas each spring. The educational and social opportunities afforded by these meetings are invaluable.. FOR MORE INFORMATION ON THE NCC: Lisa Brechtel MHI National Communities Council

3 S.A.F.E. Act Under the Secure and Fair Enforcement of Mortgage Licensing Act (SAFE Act), Congress did not intend to classify individuals performing administrative or clerical tasks as loan originators. The law specifically excludes those performing purely clerical tasks from being defined as a loan originator. Unless compensated by a lender, mortgage broker or loan originator, the law also does not consider those performing real estate brokerage activities and are registered/licensed under existing state law as loan originators (See section 1503(3); P.L ). While not directed by Congress, the Conference of State Bank Supervisors (CSBS) and the American Association of Residential Mortgage Regulators (AARMR) drafted a Model State Law (MSL) to assist states in enacting SAFE Act compliant laws. The MSL disregards legislative intent and removes the exclusion Congress intended for those performing administrative or clerical tasks. This has created substantial confusion among states in applying the SAFE Act to manufactured home salespersons and retailers, a majority of whom only perform purely administrative or clerical tasks during the home sales process. HUD s final SAFE Act rule formalizing its guidance awaits release from the Office of Management and Budget. The SAFE Act also establishes new mortgage loan originator definitions that conflict with pre-existing state law and imposes new limits on the industry s ability to provide seller carry back financing. Under the Dodd-Frank Act, the newly established Consumer Financial Protection Bureau (CFPB) will assume jurisdiction over the SAFE Act from HUD. The manufactured housing industry and the NCC fully support efforts to enhance consumer protection and promote responsible lending activities. However, confusing and contradictory treatment of mortgage originators at the federal level and lack of consistent standards in the treatment of mortgage finance products has the potential to create an unlevel playing field by penalizing those living in lower cost affordable manufactured homes over more expensive site-built housing. Legislative clarification and modification is necessary to assist states in properly and efficiently implementing the SAFE Act. MHI will continue to strongly pursue appropriate application of SAFE Act requirements.

4 Dodd-Frank Wall Street Reform And Consumer Protection Act The Dodd Frank Wall Street Reform and Consumer Protection Act (P.L ) is the most sweeping rewrite of rules governing banking and financial services in decades. It provides unprecedented authority to a new Bureau of Consumer Financial Protection (CFPB) to develop mortgage lending rules, including for manufactured home loans secured by personal property. The Act adds significant new requirements on residential mortgages, including limitations on origination activities, high cost mortgages and appraisals. While the CFPB will not officially assume regulatory control over housing finance issues until July 2011, administration officials are already in the process of drafting regulatory changes required by the Act. Unless Congress passes legislation reducing burdens the Act places on low and moderate income manufactured homeowners, the availability of credit in the manufactured housing marketplace will be substantially curtailed. MHI was successful in exempting, on a limited basis, manufactured and modular housing industry salespersons and retailers from the scope of the new agency if they are only: 1) acting as an agent or broker for a buyer or seller of a manufactured home or a modular home, or; 2) facilitating the purchase by a consumer of a manufactured home or modular home, by negotiating the purchase price or terms of the sales contract, not the financial arrangement. In late 2010, MHI established a Dodd-Frank Regulatory Reform Task Force. Sheila Dey, Executive Director of the Western MHC Association, and Ken Rishel, Director of Precision Capital Funding, currently serve as the NCC s representatives to MHI s task force. To ensure financing for manufactured housing remains affordable and available, Congress is urged to enact MHI/NCC supported legislation that will: Minimize burdensome high cost mortgage standards placed on manufactured homeowners ~ New high cost mortgage triggers in Dodd Frank restrict access to affordable manufactured housing financing for low to moderate income families. Reduce uncertainty in qualified mortgage guidelines ~ Dodd Frank defines the terms of a qualified mortgage, which are exempt from certain Dodd Frank requirements. CFPB s ability to rewrite rules without Congressional oversight coupled with vague guidelines forces the manufactured housing market to operate in an uncertain environment. Eliminate conflicting federal mortgage originator standards ~ Dodd Frank establishes new mortgage loan originator definitions that conflict with pre existing law and will cause significant confusion. Eliminate unrealistic methods for appraisal manufactured housing ~ Site built oriented appraisal requirements have little applicability to manufactured housing and ultimately penalize manufactured homeowners. Curtail potential prejudicial treatment of manufactured housing loan products ~ Manufactured housing is arbitrarily subjected to new regulations ill suited to the prevailing realities of the manufactured housing market.

5 Housing Finance Reform And Government-Sponsored Enterprises (GSEs) As required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (P.L ), in early 2011, the Administration released its recommendations on ending the conservatorship of Fannie Mae and Freddie Mac and reforming the housing finance system. For more than a decade, GSE support of manufactured home lending and finance has been limited. Even with strong Congressional guidance in the Housing and Economic Recovery Act of 2008 (HERA) which indicated the GSEs have a duty to serve the finance needs of the manufactured housing market little headway has been made to push GSEs into the business of establishing a secondary market for manufactured home loans secured by personal property. While it is unclear what system may ultimately replace the GSEs or when this may occur, MHI believes that any system private, public or public-private hybrid must fully and adequately serve the liquidity needs of the manufactured housing industry. MHI is committed to ensuring that manufactured housing loans, especially homes titled as personal property, receive the same opportunity to access capital and financing through securitization as their site-built counterparts. MHI will continue to actively work with Congress, the administration, and other external stakeholder groups at the national and grassroots level, to ensure manufactured housing is on a level playing field in any new housing finance system.

6 Carried Interest Taxation Many real estate investment funds or ventures are organized as limited partnerships. Investors typically serve as limited partners while general partners provide management and in some cases, capital. During the time that a real estate partnership s asset is held, a general partner would receive compensation and fees in the form of ordinary income. When assets are sold, however, the general partner would also receive a share of any profit, often called the carried interest, as capital gains income. The carried interest mechanism is viewed as an important tool or economic incentive for general partners, whose participation is essential in partnership structures. The real estate industry employs partnerships with carried interest on a wide variety of projects and investment ventures. Changing the tax treatment of carried interests would result in a significant tax increase for real estate partnerships President Obama s fiscal year 2010 budget proposal called for legislation to tax carried interest as ordinary income. Although this effort did not prevail, as Congress debates various tax and benefit extensions during budget considerations, those that are categorized as revenue generators continually remain vulnerable. MHI opposes any proposal that would eliminate capital gains treatment for any carried interest of a real estate partnership. MHI will continue to work with other real estate industry groups to protect and promote the value of real estate investment

7 FHA 207(m) Program Reform The FHA 207m program was designed for the development or rehabilitation of manufactured home communities, one of the most affordable housing options for millions of Americans. Financing for new communities can be very challenging, while many are also in need of financing for substantial rehabilitation. The 207m program is not a direct loan program. Rather, it is a mortgage insurance program that allows community owners and developers to obtain financing for their renewal project from approved HUD lenders by first obtaining mortgage insurance. Every year, thousands of manufactured home communities undertake substantial rehabilitation projects that would be eligible for insurance under the 207m program, yet FHA has not shown any inclination toward modernizing the program to make it more competitive in the marketplace. MHI/NCC strongly supports updating and modernizing FHA s 207(m) program to make it more competitive in the marketplace and fulfill its mission of supporting affordable housing.

8 Industry Fire Sprinkler Standard HUD is of the position that fire sprinklers are not preempted by the HUD code. MHI s TAC Committee, in response to a resolution passed in 2009 by the MHI Manufactured Housing Division, developed a proposed where required fire sprinkler standard for inclusion in the HUD code to be used in those states and local jurisdictions that require fire sprinklers in new single family homes. HUD has also proposed similar where required fire sprinkler standards. The MHI fire sprinklers proposal is pending before the Manufactured Housing Consensus Committee (MHCC). The MHCC, during its October 2010 meeting, voted to request HUD to revisit its position. It has taken the position since at least the 1990 s that fire sprinklers are not preempted by the HUD code. It also voted that the fire sprinkler proposal be sent to the Technical Structure and Design Committee for review, research and recommendation within one year. MHI has urged HUD to act expeditiously on whether it will change its position on preemption. In the meantime, MHI will continue to work with the MHCC to seek adoption of the MHI where required sprinkler provision, and to support the state manufactured housing associations that are working to keep sprinkler mandates from being required for all single family housing.

9 Section 8 Voucher Reform Currently, under Section 8 of the United States Housing Act of 1937, rental assistance payments in the form of vouchers may be used to assist certain owners of manufactured homes who rent the lots on which their homes are located. The ability of low- and moderate-income manufactured homeowners to fully access this program and benefit from federal assistance is limited by the current restrictions. MHI supports the use of the Section 8 voucher for the full cost of purchasing a manufactured home sited on leased land, by permitting funds to be used for both the cost of leasing the land, and for the monthly home purchase costs including property taxes, insurance, and tenant-paid utilities.

Revise the triggers by which small sized manufactured home loans are considered High Cost under

Revise the triggers by which small sized manufactured home loans are considered High Cost under Protect Availability of Financing for Affordable Manufactured Housing Urge Representatives to Co Sponsor the Preserving Access to Manufactured Housing Act (May 2013) BACKGROUND: Representatives Stephen

More information

GLOSSARY OF TERMS. Amortization Repayment of a debt in regular installments of principal and interest, rather than interest only payments

GLOSSARY OF TERMS. Amortization Repayment of a debt in regular installments of principal and interest, rather than interest only payments GLOSSARY OF TERMS Ability to Repay (ATR) The Ability to Repay rule protects consumers from taking on mortgages that exceed their financial means, by mandating the documentation / proof of income and assets.

More information

FROM: James Ballentine, Executive Vice President, Congressional Relations and Public Policy

FROM: James Ballentine, Executive Vice President, Congressional Relations and Public Policy James Ballentine Executive Vice President Congressional Relations and Political Affairs 202-663-5359 jballent@aba.com April 17, 2014 TO: Members of the Senate Banking Committee FROM: James Ballentine,

More information

Overview of Mortgage Lending

Overview of Mortgage Lending Chapter 1 Overview of Mortgage Lending 1 Chapter Objectives Identify historical events affecting today s mortgage industry. Contrast the primary mortgage market and secondary mortgage market. Identify

More information

A PRIMER FOR BANKERS ON THE IMPLEMENTATION OF THE SECURE AND FAIR ENFORCEMENT FOR MORTGAGE LICENSING ACT

A PRIMER FOR BANKERS ON THE IMPLEMENTATION OF THE SECURE AND FAIR ENFORCEMENT FOR MORTGAGE LICENSING ACT A PRIMER FOR BANKERS ON THE IMPLEMENTATION OF THE SECURE AND FAIR ENFORCEMENT FOR MORTGAGE LICENSING ACT John Charles Fleming Hays & Owens L.L.P. 807 Brazos Suite 500 Austin, Texas 78701 (512) 472-3993

More information

Q & A with Lykken on Lending Team and Glen Corso

Q & A with Lykken on Lending Team and Glen Corso Blog Talk Radio Show July 12, 2010 Q & A with Lykken on Lending Team and Glen Corso General Questions Q: Throughout the MBA analysis of this legislation the term loan originator is used. Sometimes it seems

More information

HUD s AFFORDABLE LENDING GOALS FOR FANNIE MAE AND FREDDIE MAC

HUD s AFFORDABLE LENDING GOALS FOR FANNIE MAE AND FREDDIE MAC Issue Brief HUD s AFFORDABLE LENDING GOALS FOR FANNIE MAE AND FREDDIE MAC Fannie Mae and Freddie Mac, government-sponsored enterprises (GSEs) in the secondary mortgage market, are the two largest sources

More information

ILLINOIS ASSOCIATION OF REALTORS HOUSING POLICY

ILLINOIS ASSOCIATION OF REALTORS HOUSING POLICY ILLINOIS ASSOCIATION OF REALTORS HOUSING POLICY ILLINOIS ASSOCIATION OF REALTORS HOUSING POLICY As an Association, we reaffirm our commitment to the goal of decent housing and a suitable living environment

More information

House Committee on Financial Services. November 29, 2012

House Committee on Financial Services. November 29, 2012 House Committee on Financial Services Joint Hearing Before the Subcommittee on Financial Institutions and Consumer Credit and the Subcommittee on Insurance, Housing and Community Opportunity Entitled Examining

More information

THE FIVE-POINT PLAN. Refocusing the Future of Minority Homeownership

THE FIVE-POINT PLAN. Refocusing the Future of Minority Homeownership THE FIVE-POINT PLAN Refocusing the Future of Minority Homeownership The Asian Real Estate Association of America (AREAA), the National Association of Hispanic Real Estate Professionals (NAHREP), and the

More information

SPECIAL ALERT: CFPB PROPOSES SIGNIFICANT EXPANSION OF HMDA REPORTING REQUIREMENTS

SPECIAL ALERT: CFPB PROPOSES SIGNIFICANT EXPANSION OF HMDA REPORTING REQUIREMENTS SPECIAL ALERT: CFPB PROPOSES SIGNIFICANT EXPANSION OF HMDA REPORTING REQUIREMENTS JULY 30, 2014 On July 24, the Consumer Financial Protection Bureau (the CFPB or Bureau) issued a proposed rule that would

More information

Summary of the Housing and Economic Recovery Act of 2008

Summary of the Housing and Economic Recovery Act of 2008 Summary of the Housing and Economic Recovery Act of 2008 On July 30, President Bush signed major housing legislation, HR 3221, the Housing and Economic Recovery Act of 2008. The bill restructures regulation

More information

Re: Docket No. CFPB-2013-0002 Proposed Amendments to the Ability-to-Repay Standards under the Truth in Lending Act (Regulation Z)

Re: Docket No. CFPB-2013-0002 Proposed Amendments to the Ability-to-Repay Standards under the Truth in Lending Act (Regulation Z) February 25, 2013 Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Docket No. CFPB-2013-0002 Proposed Amendments to the Ability-to-Repay

More information

2011 I M HOME Retreat Knoxville, TN

2011 I M HOME Retreat Knoxville, TN 2011 I M HOME Retreat Knoxville, TN 2011 I M HOME Retreat Knoxville, TN I M HOME Policy Strategy Federal Policy Strategy 1. Challenge: No new appropriations Response: Defense versus offense 2. Challenge:

More information

Support Under the Homeowner Affordability and Stability Plan: Three Cases

Support Under the Homeowner Affordability and Stability Plan: Three Cases Support Under the Homeowner Affordability and Stability Plan: Three Cases Family A: Access to Refinancing In 2006: Family A took a 30-year fixed rate mortgage of $207,000 on a house worth $260,000 at the

More information

www.caionline.org Page 1

www.caionline.org Page 1 Thomas M. Skiba, CAE Chief Executive Officer Community Associations Institute Statement for the Record Hearing Entitled: The Future of Housing in America Federal Housing Reforms that Create Housing Opportunity

More information

Guide to Fair Mortgage Lending and Home Preservation

Guide to Fair Mortgage Lending and Home Preservation Guide to Fair Mortgage Lending and Home Preservation Fair Housing Legal Support Center & Clinic Guide to Fair Mortgage Lending and Home Preservation What does this guide cover? What is Fair Lending? What

More information

H.R. 3965 Mark-to-Market Extension and Enhancement Act of 2007

H.R. 3965 Mark-to-Market Extension and Enhancement Act of 2007 CONGRESSIONAL BUDGET OFFICE COST ESTIMATE November 30, 2007 H.R. 3965 Mark-to-Market Extension and Enhancement Act of 2007 As ordered reported by the House Committee on Financial Services on October 31,

More information

S. 3085 Responsible Homeowner Refinancing Act of 2012

S. 3085 Responsible Homeowner Refinancing Act of 2012 CONGRESSIONAL BUDGET OFFICE COST ESTIMATE August 24, 2012 S. 3085 Responsible Homeowner Refinancing Act of 2012 As introduced in the United States Senate on May 10, 2012 SUMMARY The Home Affordable Refinance

More information

Community Mortgage Banking Project

Community Mortgage Banking Project July 1, 2010 Robert E. Feldman Executive Secretary Federal Deposit Insurance Corporation 550 17 th Street, NW., Washington, DC 20429 Re: RIN 3064 AD53 Dear Mr. Feldman: The Community Mortgage Banking Project

More information

A Presentation On the State of the Real Estate Crisis 1/30/2009

A Presentation On the State of the Real Estate Crisis 1/30/2009 A Presentation On the State of the Real Estate Crisis 1/30/2009 Presented by Mike Anderson, CRMS President, Essential Mortgage, a Latter & Blum Realtors Company Immediate past president/legislative Chair

More information

Glossary of Foreclosure Fairness Mediation Terminology

Glossary of Foreclosure Fairness Mediation Terminology Glossary of Foreclosure Fairness Mediation Terminology Adjustable-Rate Mortgage (ARM) Mortgage repaid at the rate of interest that increases or decreases over the life of the loan based on market conditions.

More information

CFPB Consumer Laws and Regulations

CFPB Consumer Laws and Regulations Secure and Fair Enforcement for Mortgage Licensing Act 1 The Secure and Fair Enforcement for Mortgage Licensing Act of 2008 2 () was enacted on July 30, 2008, and mandates a nationwide licensing and registration

More information

Regulation of Real Estate Appraisers

Regulation of Real Estate Appraisers Edward V. Murphy Specialist in Financial Economics June 26, 2012 CRS Report for Congress Prepared for Members and Committees of Congress Congressional Research Service 7-5700 www.crs.gov RS22953 Summary

More information

Valuation for Mortgage Lending in North America and Lessons for Europe. Presented to The European Group of Valuers Associations Berlin -- April 2015

Valuation for Mortgage Lending in North America and Lessons for Europe. Presented to The European Group of Valuers Associations Berlin -- April 2015 Valuation for Mortgage Lending in North America and Lessons for Europe Presented to The European Group of Valuers Associations Berlin -- April 2015 Home Ownership in the U.S. 14% of the U.S. population

More information

Table of Contents. Table of Contents... 1. Chapter 1 Introduction... 3. 1.1 Goals & Objectives... 3 1.2 Required Review... 3 1.3 Applicability...

Table of Contents. Table of Contents... 1. Chapter 1 Introduction... 3. 1.1 Goals & Objectives... 3 1.2 Required Review... 3 1.3 Applicability... [ Client]... 1 Chapter 1 Introduction... 3 1.1 Goals & Objectives... 3 1.2 Required Review... 3 1.3 Applicability... 4 Chapter 2 Accountability and Monitoring... 5 2.1 Internal Controls... 5 Chapter 3

More information

RE: Proposed Minimum Requirements for Appraisal Management Companies (AMCs)

RE: Proposed Minimum Requirements for Appraisal Management Companies (AMCs) June 9, 2014 Legislative and Regulatory Activities Division Office of the Comptroller of the Currency 400 7 th Street, SW, Suite 3E 218, Mail Stop 9W 11 Washington, DC 20219 Docket ID OCC 2014 0002 Robert

More information

BORROWER Q&AS. 2. I'm current on my mortgage. Will the Home Affordable Refinance help me?

BORROWER Q&AS. 2. I'm current on my mortgage. Will the Home Affordable Refinance help me? MAKING HOME AFFORDABLE BORROWER Q&AS 1. What is Making Home Affordable" all about? Making Home Affordable is part of President Obama's comprehensive strategy to get the housing market back on track. Through

More information

QCommission Sample Plans Mortgage Broker Industry

QCommission Sample Plans Mortgage Broker Industry QCommission Sample Plans Mortgage Broker Industry Introduction The mortgage industry is primarily involved in providing loans to consumers. This industry is made up of many parts, governmental entities

More information

S. 720 Energy Savings and Industrial Competitiveness Act of 2015

S. 720 Energy Savings and Industrial Competitiveness Act of 2015 CONGRESSIONAL BUDGET OFFICE COST ESTIMATE October 19, 2015 S. 720 Energy Savings and Industrial Competitiveness Act of 2015 As reported by the Senate Committee on Energy and Natural Resources on September

More information

GOVERNMENT-SPONSORED ENTERPRISES

GOVERNMENT-SPONSORED ENTERPRISES GOVERNMENT-SPONSORED ENTERPRISES This chapter contains descriptions of the data on the Government-sponsored enterprises listed below. These enterprises were established and chartered by the Federal Government

More information

Dodd-Frank: What About Leasing? October 2011 By Paul Bent. Part Two of a Two-Part Article

Dodd-Frank: What About Leasing? October 2011 By Paul Bent. Part Two of a Two-Part Article Dodd-Frank: What About Leasing? October 2011 By Paul Bent Part Two of a Two-Part Article Part One of this two-part article provided an overview of the Dodd-Frank Wall Street Reform and Consumer Protection

More information

Conventional Financing for Manufactured Homes. Consider the Future of Housing Finance. Submitted to U.S. House Financial Services Committee

Conventional Financing for Manufactured Homes. Consider the Future of Housing Finance. Submitted to U.S. House Financial Services Committee Conventional Financing for Manufactured Homes Consider the Future of Housing Finance Submitted to U.S. House Financial Services Committee Submitted by Andrea Levere President CFED 1200 G Street, NW Suite

More information

GOVERNMENT-SPONSORED ENTERPRISES

GOVERNMENT-SPONSORED ENTERPRISES GOVERNMENT-SPONSORED ENTERPRISES This chapter contains descriptions of the data on the Governmentsponsored enterprises listed below. These enterprises were established and chartered by the Federal Government

More information

THE APPLICABILITY OF HMFACTS PRODUCTS AND TOOLS AND THE EFFECTS OF H.R.

THE APPLICABILITY OF HMFACTS PRODUCTS AND TOOLS AND THE EFFECTS OF H.R. WHITE PAPER THE APPLICABILITY OF HMFACTS PRODUCTS AND TOOLS AND THE EFFECTS OF H.R. 4173 DODD-FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT ON INDUSTRY PROFESSIONALS. Presented By: Decision Ready

More information

RE: RIN 2900 AO65 Loan Guaranty: Ability-to-Repay Standards and Qualified Mortgage Definition under the Truth in Lending Act

RE: RIN 2900 AO65 Loan Guaranty: Ability-to-Repay Standards and Qualified Mortgage Definition under the Truth in Lending Act June 9, 2014 Mr. John Bell Assistant Director for Loan Policy and Valuation Veterans Benefits Administration, Department of Veterans Affairs 810 Vermont Avenue, NW Washington, DC 20420 RE: RIN 2900 AO65

More information

Housing & Government Sponsored Enterprises. FY 2017 President s Budget

Housing & Government Sponsored Enterprises. FY 2017 President s Budget Housing & Government Sponsored Enterprises FY 2017 President s Budget February 9, 2016 Table of Contents Section 1 Purpose... 3 1A Mission Statement... 3 1.1 Program Account Summary... 3 1.2 Financing

More information

Dodd Frank Act Consumer Financial Protection Bureau Mortgage Lending

Dodd Frank Act Consumer Financial Protection Bureau Mortgage Lending Dodd Frank Act Consumer Financial Protection Bureau Mortgage Lending A Briefing for the Texas House Investments and Financial Services Committee John C. Fleming Consumer Financial Protection Bureau (CFPB)

More information

Progress and Peril III: Taking Action: A Status Report on the Compact for Home Opportunity

Progress and Peril III: Taking Action: A Status Report on the Compact for Home Opportunity Progress and Peril III: Taking Action: A Status Report on the Compact for Home Opportunity Executive Summary This status report describes progress toward implementation of the Compact for Home Opportunity,

More information

Prince William County Home Help Plus Program

Prince William County Home Help Plus Program Prince William County Home Help Plus Program Prince William County Office of Housing & Community Development Elijah T. Johnson, Director 15941 Donald Curtis Drive, Suite 112 Woodbridge, Virginia 22191

More information

Mortgage-backed Securities

Mortgage-backed Securities MÄLARDALEN UNIVERSITY PROJECT DEPARTMENT OF MATHEMATICS AND PHYSICS ANALYTICAL FINANCE, MT 1411 TEACHER: JAN RÖMAN 2004-12-16 Mortgage-backed Securities GROUP : CAROLINA OLSSON REBECCA NYGÅRDS-KERS ABSTRACT

More information

House Republican Housing Plan The Responsible Homeowners Act

House Republican Housing Plan The Responsible Homeowners Act House Republican Housing Plan The Responsible Homeowners Act Keeping Families in Their Home, Lowering Costs for All Homeowners: $5,000 Refinancing Credit: House Republicans propose to provide a $5,000

More information

Fiduciary Standards: The best choice for Main Street investors? National Association of Insurance and Financial Advisors

Fiduciary Standards: The best choice for Main Street investors? National Association of Insurance and Financial Advisors Fiduciary Standards: The best choice for Main Street investors? National Association of Insurance and Financial Advisors Fiduciary Standards: Do consumers need or want costly solutions in search of a problem?

More information

Title XIV - Mortgage Reform and Anti-Predatory Lending Act. Short title: "Mortgage Reform and Anti-Predatory Lending Act"

Title XIV - Mortgage Reform and Anti-Predatory Lending Act. Short title: Mortgage Reform and Anti-Predatory Lending Act Title XIV - Mortgage Reform and Anti-Predatory Lending Act Short title: "Mortgage Reform and Anti-Predatory Lending Act" Subtitles A, B, C, and E are designated as Enumerated Consumer Law under the Bureau

More information

NEW MORTGAGE RULES DEMYSTIFIED: WHAT EVERY AGENT NEEDS TO KNOW BEFORE JANUARY

NEW MORTGAGE RULES DEMYSTIFIED: WHAT EVERY AGENT NEEDS TO KNOW BEFORE JANUARY Real Estate Agent Webinar White Paper NEW MORTGAGE RULES DEMYSTIFIED: WHAT EVERY AGENT NEEDS TO KNOW BEFORE JANUARY On December 10, 2013 PNC Mortgage hosted an educational webinar for real estate agents

More information

PACE and the Federal Housing Finance Agency (FHFA)

PACE and the Federal Housing Finance Agency (FHFA) MARCH 17, 2010 PACE and the Federal Housing Finance Agency (FHFA) By Mark Zimring and Merrian Fuller The FHFA regulates Fannie Mae, Freddie Mac, and the 12 Federal Home Loan Banks (the government-sponsored

More information

Financing Residential Real Estate: SAFE Comprehensive 20 Hours

Financing Residential Real Estate: SAFE Comprehensive 20 Hours Financing Residential Real Estate: SAFE Comprehensive 20 Hours COURSE ORGANIZATION and DESIGN Roy L. Ponthier, Ph.D., Ed.D., CDEI, DREI Executive Director Module 1: Finance and Investment Mortgage loans

More information

How Are the Federal SAFE Act, the Federal Truth in Lending Act, State Loan Originator Regulation, and Manufactured Housing Related?

How Are the Federal SAFE Act, the Federal Truth in Lending Act, State Loan Originator Regulation, and Manufactured Housing Related? How Are the Federal SAFE Act, the Federal Truth in Lending Act, State Loan Originator Regulation, and Manufactured Housing Related? December 2015 I. Introduction For purposes of manufactured housing, there

More information

CUNA s COMPLIANCE HIGHLIGHTS

CUNA s COMPLIANCE HIGHLIGHTS CUNA s COMPLIANCE HIGHLIGHTS TILA/RESPA INTEGRATED MORTGAGE DISCLOSURES For more than 30 years, Federal law has required lenders to provide two different disclosure forms to consumers applying for a mortgage.

More information

Statement of Edward L. Golding Senior Vice President Economics and Policy Freddie Mac

Statement of Edward L. Golding Senior Vice President Economics and Policy Freddie Mac Statement of Edward L. Golding Senior Vice President Economics and Policy Freddie Mac Hearing of the Philadelphia, PA Chair Warren and members of the, thank you for inviting me to speak today. I am Edward

More information

DRAFT WORKING GROUP STIMULUS PLAN UPDATED 02-02-09

DRAFT WORKING GROUP STIMULUS PLAN UPDATED 02-02-09 DRAFT WORKING GROUP STIMULUS PLAN UPDATED 02-02-09 MODERNIZING U.S. TAX CODE TO CREATE JOBS: Cost or CBO Score Description of Tax Provisions $330 Billion Eliminate the 3.1% payroll tax for all American

More information

Statement for the Record. American Bankers Association. Committee on Small Business. United States House of Representatives

Statement for the Record. American Bankers Association. Committee on Small Business. United States House of Representatives Statement for the Record On behalf of the American Bankers Association before the Committee on Small Business of the United States House of Representatives Statement for the Record On behalf of the American

More information

MARCH 7, 2007. Madame Chairwoman and members of the Subcommittee, I appreciate the

MARCH 7, 2007. Madame Chairwoman and members of the Subcommittee, I appreciate the STATEMENT OF KEITH PEDIGO, DIRECTOR LOAN GUARANTY SERVICE VETERANS BENEFITS ADMINISTRATION BEFORE THE SUBCOMMITTEE ON ECONOMIC OPPORTUNITY HOUSE COMMITTEE ON VETERANS AFFAIRS MARCH 7, 2007 Madame Chairwoman

More information

Making Home Affordable Updated Detailed Program Description

Making Home Affordable Updated Detailed Program Description Making Home Affordable Updated Detailed Program Description The deep contraction in the economy and in the housing market has created devastating consequences for homeowners and communities throughout

More information

Report of Audit OFFICE OF INSPECTOR GENERAL. Approval Process of Funding Corporation Debt Issuances A-11-02. Tammy Rapp Auditor-in-Charge

Report of Audit OFFICE OF INSPECTOR GENERAL. Approval Process of Funding Corporation Debt Issuances A-11-02. Tammy Rapp Auditor-in-Charge OFFICE OF INSPECTOR GENERAL Report of Audit Approval Process of Funding Corporation Debt Issuances A-11-02 Tammy Rapp Auditor-in-Charge September 12, 2011 FARM CREDIT ADMINISTRATION Farm Credit Administration

More information

CFPB FINAL RULES SUN WEST IMPLEMENTATION GUIDE

CFPB FINAL RULES SUN WEST IMPLEMENTATION GUIDE CFPB FINAL RULES SUN WEST IMPLEMENTATION GUIDE January 02, 2015 In case of any queries regarding the information available in this guide, please reach us at qmteam@swmc.com. Sun West Mortgage Company,

More information

Purchase Funded (Delegated UW)

Purchase Funded (Delegated UW) Lender: Lender Requirements: $250 Application Processing Fee (Non Refundable) Minimum 2 years in business (Housing Finance Agency recommendation needed if less than 2 years) Minimum 2 years history (2

More information

MULTIFAMILY FINANCE REFORM: MOVING TO A SOLUTION IN 2013

MULTIFAMILY FINANCE REFORM: MOVING TO A SOLUTION IN 2013 MULTIFAMILY FINANCE REFORM: MOVING TO A SOLUTION IN 2013 June 24, 2013 Table of Contents Draft for Discussion Only Section Title Page 1 Proposal 3 2 Multifamily Transition 6 3 Appendix 15 Page : 2 Section

More information

Financial Services Update May 21, 2014

Financial Services Update May 21, 2014 Financial Services Update May 21, 2014 HIGHLIGHTS Federal Regulatory Developments VA Issues Its Qualified Mortgage Rule Freddie Mac Outlines Seller/Servicer Guide Changes In Bulletin 2014-6 Revised Examination

More information

KEY GSE REFORM POINTS BASED ON NAR

KEY GSE REFORM POINTS BASED ON NAR INTRODUCTION On behalf of the 1.1 million members of the NATIONAL ASSOCIATION OF REALTORS (NAR), thank you for holding this hearing on the need for reform of our Nation s housing finance system. My name

More information

May 13, 2014. Division of Conservatorship

May 13, 2014. Division of Conservatorship T H E 2 0 1 4 S T R A T E G I C P L A N F O R T H E C O N S E R V A T O R S H I P S O F F A N N I E M A E A N D F R E D D I E M A C May 13, 2014 Division of Conservatorship T A B L E O F C O N T E N T

More information

Consumer Protection and Regulatory Changes in the Dodd-Frank Bill

Consumer Protection and Regulatory Changes in the Dodd-Frank Bill 31 August 2010 Part II of A NERA Insights Series Consumer Protection and Regulatory Changes in the Dodd-Frank Bill By Dr. Ethan Cohen-Cole Summary On 21 July 2010, President Obama signed into law the Dodd-Frank

More information

A PRIMER ON THE SECONDARY MORTGAGE MARKET

A PRIMER ON THE SECONDARY MORTGAGE MARKET ONE FANEUIL HALL MARKETPLACE BOSTON, MA 02109 TEL. 617 367-4390 FAX 617 720-0918 WWW.CITYRESEARCH.COM A PRIMER ON THE SECONDARY MORTGAGE MARKET National Community Development Initiative Meetings New York,

More information

NMHC/NAA Multifamily Analysis: Bipartisan Johnson-Crapo Legislation

NMHC/NAA Multifamily Analysis: Bipartisan Johnson-Crapo Legislation NMHC/NAA Multifamily Analysis: Bipartisan Johnson-Crapo Legislation Background Senate Banking Committee Chairman Tim Johnson, D-S.D., and Ranking Member Mike Crapo, R- Idaho, released draft legislation

More information

December 22, 2010. Dear Ms. Johnson,

December 22, 2010. Dear Ms. Johnson, December 22, 2010 Jennifer J. Johnson Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington, DC 20551 Docket No. R 1390, Dear Ms. Johnson, The Conference

More information

Appraiser Independence Requirements Frequently Asked Questions (FAQs) November 2010

Appraiser Independence Requirements Frequently Asked Questions (FAQs) November 2010 Appraiser Independence Requirements Frequently Asked Questions (FAQs) November 2010 The Appraiser Independence Requirements (AIR) were developed by Fannie Mae, the Federal Housing Finance Agency (FHFA),

More information

Fin 5413: Chapter 8 Mortgage Underwriting

Fin 5413: Chapter 8 Mortgage Underwriting Fin 5413: Chapter 8 Mortgage Underwriting Some Basic Mortgage Underwriting Questions Who should you grant a loan to? How do we determine the appropriate interest rate for a loan? What is the maximum dollar

More information

SELLER FINANCING: WHEN DO THE SAFE ACT AND DODD FRANK ACT NOT APPLY. John Fleming. Law Office of John Fleming. 700 Lavaca, Suite 1400

SELLER FINANCING: WHEN DO THE SAFE ACT AND DODD FRANK ACT NOT APPLY. John Fleming. Law Office of John Fleming. 700 Lavaca, Suite 1400 SELLER FINANCING: WHEN DO THE SAFE ACT AND DODD FRANK ACT NOT APPLY John Fleming Law Office of John Fleming 700 Lavaca, Suite 1400 Austin, Texas 78701 Ph (512) 320-9110 Email: john@johnfleminglaw.com Mr.

More information

STATEMENT OF THE NATIONAL ASSOCIATION OF HOME BUILDERS. Hearing Entitled: Appraisal Oversight: The Regulatory Impact on Consumers and Businesses

STATEMENT OF THE NATIONAL ASSOCIATION OF HOME BUILDERS. Hearing Entitled: Appraisal Oversight: The Regulatory Impact on Consumers and Businesses STATEMENT OF THE NATIONAL ASSOCIATION OF HOME BUILDERS Hearing Entitled: Appraisal Oversight: The Regulatory Impact on Consumers and Businesses Subcommittee on Insurance, Housing and Community Opportunity

More information

Bureau of Real Estate SAFE ACT Frequently Asked Questions

Bureau of Real Estate SAFE ACT Frequently Asked Questions Bureau of Real Estate SAFE ACT Frequently Asked Questions Revised 9/20/13 Do the New MLO License Endorsement Requirements Apply to Me? Q. What is the definition of mortgage loan originator? A. Mortgage

More information

Talking Points: Leasehold Depreciation

Talking Points: Leasehold Depreciation Talking Points: Leasehold Depreciation Current Law: Beginning January 1, 2015, tenant improvements must be depreciated on a 39-year depreciation schedule. BOMA Position: Depreciating leasehold improvements

More information

Mortgage Lending Basics

Mortgage Lending Basics Welcome to PMI s On Demand Training Bootcamp Mortgage Lending Basics PRESENTED BY PMI MORTGAGE INSURANCE CO. Introduction to Mortgage Lending Course Overview Mortgage Lending Basics Origination Process

More information

GLOSSARY COMMONLY USED REAL ESTATE TERMS

GLOSSARY COMMONLY USED REAL ESTATE TERMS GLOSSARY COMMONLY USED REAL ESTATE TERMS Adjustable-Rate Mortgage (ARM): a mortgage loan with an interest rate that is subject to change and is not fixed at the same level for the life of the loan. These

More information

Howard S. Altarescu. Profile. Practices. Education. Honors. Partner New York (212) 506-5315

Howard S. Altarescu. Profile. Practices. Education. Honors. Partner New York (212) 506-5315 Partner New York (212) 506-5315 Profile Howard Altarescu serves as Co-Head of Orrick s global Finance Business Unit, which includes its Banking and Finance, Public Finance, Real Estate, Restructuring and

More information

NEIGHBORHOOD LAND BANK

NEIGHBORHOOD LAND BANK NEIGHBORHOOD LAND BANK Purpose: Contribute to the community stabilization, revitalization and preservation of San Diego County s communities, particularly San Diego s low and moderate income communities,

More information

The term mid-size advisor refers to a registered investment advisors with assets under management between $25 million and $100 million.

The term mid-size advisor refers to a registered investment advisors with assets under management between $25 million and $100 million. VIA ELECTRONIC MAIL Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 RE: File Number S7-36-10 Rules Implementing Amendments to the Investment

More information

PUBLIC LAW 110 185 FEB. 13, 2008

PUBLIC LAW 110 185 FEB. 13, 2008 PUBLIC LAW 110 185 FEB. 13, 2008 122 STAT. 613 Public Law 110 185 110th Congress An Act To provide economic stimulus through recovery rebates to individuals, incentives for business investment, and an

More information

CFPB proposes amendments to the ability-to-repay and qualified mortgage rules

CFPB proposes amendments to the ability-to-repay and qualified mortgage rules 1 MARCH 15, 2013 CFPB proposes amendments to the ability-to-repay and qualified mortgage rules By Raymond J. Gustini and Lloyd H. Spencer The Consumer Financial Protection Bureau ( CFPB or the Bureau )

More information

Chapter 10 6/16/2010. Mortgage Types and Borrower Decisions: Overview Role of the secondary market. Mortgage types:

Chapter 10 6/16/2010. Mortgage Types and Borrower Decisions: Overview Role of the secondary market. Mortgage types: Mortgage Types and Borrower Decisions: Overview Role of the secondary market Chapter 10 Residential Mortgage Types and Borrower Decisions Mortgage types: Conventional mortgages FHA mortgages VA mortgages

More information

Broker Quality Control Policy Manual Table of Contents. Table of Contents. [Sample Client]

Broker Quality Control Policy Manual Table of Contents. Table of Contents. [Sample Client] TABLE OF CONTENTS... 1 CHAPTER 1 INTRODUCTION... 3 1.1 GOALS AND OBJECTIVES... 3 1.2 REQUIRED REVIEW... 3 1.3 APPLICABILITY... 3 CHAPTER 2 ACCOUNTABILITY AND MONITORING... 4 2.1 INTERNAL CONTROLS... 4

More information

38464 Federal Register / Vol. 76, No. 126 / Thursday, June 30, 2011 / Rules and Regulations

38464 Federal Register / Vol. 76, No. 126 / Thursday, June 30, 2011 / Rules and Regulations 38464 Federal Register / Vol. 76, No. 126 / Thursday, June 30, 2011 / Rules and Regulations DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 24 CFR Parts 30 and 3400 [Docket No. FR 5271 F 03] RIN 2502 A170

More information

Mortgage Banking. Solutions in Compliance, Transactions, and Defense. Attorney Advertising

Mortgage Banking. Solutions in Compliance, Transactions, and Defense. Attorney Advertising Mortgage Banking Solutions in Compliance, Transactions, and Defense Attorney Advertising The mortgage banking industry is changing rapidly. We offer broad regulatory experience, formidable skill in litigation,

More information

P r i m e r : Agency Bonds

P r i m e r : Agency Bonds P r i m e r : Agency Bonds j a n n e y corporat e credit F e b r u a ry 5, 2014 Agencies provide extra yield vs. Treasuries, offer predictable and relatively safe income, and can be a part of a diversified

More information

Financing Residential Real Estate

Financing Residential Real Estate Financing Residential Real Estate Chapter 1: Finance and Investment Borrowing Money to Buy a Home Investments and Returns Types of Investments Ownership Investments Debt Investments Securities Investment

More information

The New Mortgage Servicing Rules. FMS East Coast Regional Conference September 17, 2013

The New Mortgage Servicing Rules. FMS East Coast Regional Conference September 17, 2013 The New Mortgage Servicing Rules FMS East Coast Regional Conference September 17, 2013 What are the new Mortgage Servicing Rules? Ability to Repay/Qualified Mortgage Rule 2013 HOEPA Rule Loan Originator

More information

APRIL 10, 2012. Worldwide ERC would like to thank today s sponsor: 2012 Worldwide ERC

APRIL 10, 2012. Worldwide ERC would like to thank today s sponsor: 2012 Worldwide ERC APRIL 10, 2012 Worldwide ERC would like to thank today s sponsor: 2012 Worldwide ERC TRENDS IN THE MORTGAGE INDUSTRY AND THE IMPACT ON THE RELOCATION BUSINESS 2012 Worldwide ERC Welcome and Learning Zone

More information

White Paper: HB 631/SB 666 Loan Originators, Mortgage Brokers, & Mortgage Lenders

White Paper: HB 631/SB 666 Loan Originators, Mortgage Brokers, & Mortgage Lenders White Paper: HB 631/SB 666 Loan Originators, Mortgage Brokers, & Mortgage Lenders I. Overview The explosion in subprime lending was a major factor that led to the Great Recession from 2007 to 2009. The

More information

Homeowner Flood Insurance Affordability Act of 2014 Section by Section Summary

Homeowner Flood Insurance Affordability Act of 2014 Section by Section Summary Homeowner Flood Insurance Affordability Act of 2014 Section by Section Summary On March 21, 2014, President Obama signed into law the Homeowner Flood Insurance Affordability Act of 2014 (HIFAA) (P.L. 113-89).

More information

Your Rights Under the Protecting Tenants at Foreclosure Act

Your Rights Under the Protecting Tenants at Foreclosure Act Your Rights Under the Protecting Tenants at Foreclosure Act Are you a renting a house that is in foreclosure or has been foreclosed? Under the Protecting Tenants at Foreclosure Act (PTFA) a new owner needs

More information

Policy Guidance on Supervisory and Enforcement Considerations Relevant to Mortgage

Policy Guidance on Supervisory and Enforcement Considerations Relevant to Mortgage BILLING CODE: 4810-AM-P BUREAU OF CONSUMER FINANCIAL PROTECTION Policy Guidance on Supervisory and Enforcement Considerations Relevant to Mortgage Brokers Transitioning to Mini-Correspondent Lenders AGENCY:

More information

RE: Loans in Areas Having Special Flood Hazards

RE: Loans in Areas Having Special Flood Hazards December 29, 2014 Robert dev. Frierson Secretary Board of Governors of the Federal Reserve System 20 th Street and Constitution Ave., NW Washington DC 20551 Docket No. R-1498 Legislative & Regulatory Activities

More information

FOR IMMEDIATE RELEASE November 7, 2013 MEDIA CONTACT: Lisa Gagnon 703-903-3385 INVESTOR CONTACT: Robin Phillips 571-382-4732

FOR IMMEDIATE RELEASE November 7, 2013 MEDIA CONTACT: Lisa Gagnon 703-903-3385 INVESTOR CONTACT: Robin Phillips 571-382-4732 FOR IMMEDIATE RELEASE MEDIA CONTACT: Lisa Gagnon 703-903-3385 INVESTOR CONTACT: Robin Phillips 571-382-4732 FREDDIE MAC REPORTS PRE-TAX INCOME OF $6.5 BILLION FOR THIRD QUARTER 2013 Release of Valuation

More information

Early Summary of Ability to Repay and Qualified Mortgage Rules under Dodd-Frank Wall Street Reform and Consumer Protection Act.

Early Summary of Ability to Repay and Qualified Mortgage Rules under Dodd-Frank Wall Street Reform and Consumer Protection Act. Early Summary of Ability to Repay and Qualified Mortgage Rules under Dodd-Frank Wall Street Reform and Consumer Protection Act January 11, 2013 OVERVIEW - On January 10, 2013, the Consumer Financial Protection

More information

January 15, 2016. Honorable Richard Cordray, Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552

January 15, 2016. Honorable Richard Cordray, Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 January 15, 2016 Honorable Richard Cordray, Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 Re: Request for Formal CFPB Review of Banking Agencies Decision to Consider

More information

STREET CAPITAL FINANCIAL CORPORATION STREET CAPITAL HOLDINGS CORPORATION STREET CAPITAL MORTGAGE CORPORATION

STREET CAPITAL FINANCIAL CORPORATION STREET CAPITAL HOLDINGS CORPORATION STREET CAPITAL MORTGAGE CORPORATION STREET CAPITAL FINANCIAL CORPORATION STREET CAPITAL HOLDINGS CORPORATION STREET CAPITAL MORTGAGE CORPORATION (Collectively referred to as Street Capital) CONFLICT OF INTEREST AND MORTGAGE SUITABILITY POLICY

More information

2. Low and Moderate Income and Other Affordable Housing Programs

2. Low and Moderate Income and Other Affordable Housing Programs This notice was modified on March 5, 2012. Department of Revenue Modification of Revenue Notice # 01-05: Mortgage Registry Tax Exemption for Mortgages that Secure Loans Made Under Qualifying Government

More information

Statement of. David Hehman President and CEO Federal Home Loan Bank of Cincinnati. Before the. House Financial Services Committee

Statement of. David Hehman President and CEO Federal Home Loan Bank of Cincinnati. Before the. House Financial Services Committee Statement of David Hehman President and CEO Federal Home Loan Bank of Cincinnati Before the House Financial Services Committee September 25, 2003 Mr. Chairman, Ranking Member Frank, and Members of the

More information

Get Your Multifamily Deal Done With FHA

Get Your Multifamily Deal Done With FHA January 7, 2009 Get Your Multifamily Deal Done With FHA Arbor Commercial Mortgage, LLC Overview In 2008, the housing finance system came to a near standstill as creditors began losing confidence in the

More information

J.P. Morgan FinTech and Specialty Finance Forum December 2015

J.P. Morgan FinTech and Specialty Finance Forum December 2015 J.P. Morgan FinTech and Specialty Finance Forum December 2015 Forward-Looking Statements This presentation contains forward-looking statements within the meaning of Section 21E of the Securities Exchange

More information

MORTGAGE TERMS. Assignment of Mortgage A document used to transfer ownership of a mortgage from one party to another.

MORTGAGE TERMS. Assignment of Mortgage A document used to transfer ownership of a mortgage from one party to another. MORTGAGE TERMS Acceleration Clause This is a clause used in a mortgage that can be enforced to make the entire amount of the loan and any interest due immediately. This is usually stipulated if you default

More information