2 Agenda HPML Appraisal Requirements High Cost Mortgage QM Points and Fees QM Cure Provision HPML Escrow Requirements HMDA Revisions Loan Estimate Form Closing Disclosure Restriction on Fees Escrow Closing Notice Partial Payment Disclosure Integrated Mortgage Disclosures Recent Final Rules HMDA Proposed Revisions Mortgage Servicing Proposed Revisions
3 HPML Appraisal Requirements
4 HPML Appraisal Requirements Effective January 1, 2015 Higher-Priced Mortgage Loan (HPML) Adjusted exemption threshold increased from $25,000 to $25,500. Exemption threshold for smaller loans adjusted based on annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) that was in effect on the preceding June 1.
5 HPML Appraisal Requirements Higher-Priced Mortgage Loans (HPML) A high-priced mortgage loan (HPML) is a consumer credit transaction secured by the consumer s principal dwelling with an APR that exceeds the APOR by: 1.5 or more percentage points for a first lien (non-jumbo) 2.5 or more percentage points for a first lien jumbo loan*; 3.5 or more percentage points for a subordinate lien *A loan is a jumbo loan when the principal balance exceeds the limit in effect as of the date the transaction s rate is set for the maximum principal obligation eligible for purchase by Freddie Mac.
6 HPML Appraisal Requirements Loans EXEMPT from appraisal requirements: Qualified Mortgages (QMs) Reverse mortgages Bridge loans (for 12 months or less and intended to be used to acquire a new principal dwelling) Loans for initial construction of a dwelling (not limited to loans of 12 months or less) Loans secured by new manufactured homes Loans secured by boats, trailers, and mobile homes loans
7 HPML Appraisal Requirements Three NEW Exemptions were added after the final rule was adopted (January 2014): Extensions of credit of $25,500 or less Exemption for Certain Refinancings - Streamlined refinancings Transactions secured in whole or in part by a manufactured home - Effective July 18, 2015 * Transactions secured by an existing (used) manufactured home and land will NOT be exempt from the rules. *
8 HPML Appraisal Requirements Appraisal Requirements: Disclose to members within three business days after receiving the members applications that they are entitled to a free copy of any appraisal the credit union orders and also they can hire their own appraiser at their own expense for their own use. Obtain a written appraisal performed by certified or licensed appraiser in conformity with the USPAP and Title XI of FIRREA and its implementing regulations. Have the appraiser visit the interior of the property and provide a written report. Deliver copies of appraisals to applicants no later than three business days before consummation.
9 HOEPA Coverage High Cost Mortgage
10 HOEPA Coverage High Cost Mortgage Points and Fees Test Effective January 1, 2015 A transaction is high-cost if its points and fees exceed: 5% of the total loan amount for a loan greater than or equal to $20,391 8% of the total loan amount or $1,020 (whichever is less) for a loan amount less than $20,391 What is included in points and fees calculation? Closed end same as for QM/ATR rule. Open end same as closed-end, but also include participation fees, fees you may charge for draws (assuming at least 1 draw).
11 HOEPA Coverage High-Cost Mortgage If you determine you have a high cost mortgage: Specific disclosure requirements Restriction of transaction terms Restrictions on fees and practices Ability-to-repay requirements Pre-loan counseling requirement
12 Qualified Mortgages (QM) Points and Fees Threshold
13 QM - Points and Fees Effective January 1, 2015 For a loan to be a QM, the points and fees cannot exceed: Loan Amount Points and Fees Limit $101,953 or more 3% $61,172 - $101, $3,059 $20,391 - $61, % $12,744 - $20, $1,020 $12, or less 8%
14 QM- Points and Fees To calculate the points and fees you will add together the amounts paid in connection with the transaction including: 1. Finance charges Charges that can be excluded: Interest or time-price differential Mortgage insurance premiums (MIP) Federal or State government sponsored MIP (up front and annual FHA premiums, VA funding fees, etc.) PMI premiums (exception for FHA loans) Bona fide third party charges not retained by the creditor, LO or affiliate of either
15 QM - Points and Fees 1. Finance charges (cont d): Charges that can be excluded: Bona fide discount points Exclude up to 2 points IF the interest rate before the discount does not exceed the APOR for a comparable transaction by more than 1% point Exclude up to 1 point IF the interest rate before the discount does not exceed the APOR for a comparable transaction by more than 2% points. 2. LO Compensation Include compensation paid directly or indirectly by a member or a creditor to a loan originator OTHER than compensation paid by a mortgage broker, creditor or retailer of manufactured homes to an employee.
16 QM - Points and Fees 3. Real Estate Related Fees Charges can be excluded IF: The charge is reasonable; The credit union receives no direct or indirect compensation in connection with the charge; and The charge is not paid to an affiliate of the credit union. If one or more of those conditions is NOT satisfied you must include these charges, even if they would be excluded from the finance charge: Fees for title examination (abstract of title, title insurance, etc.) Fees for preparing loan-related docs (deeds, mortgages) Notary and credit report fees Property appraisal or inspection fees Amounts paid into escrow (that are not otherwise included in finance charge)
17 QM - Points and Fees 4. Premiums for credit insurance (life, accident, credit property) Include for these types of insurance that are payable at or before consummation even if they are rolled into the loan amount (if permitted by law) No need to include if paid after consummation (monthly premiums) No need to include premiums for life, accident, health or loss of income insurance if the member (or another person designated by the member) is the sole beneficiary of the insurance.
18 QM - Points and Fees 5. Maximum Prepayment penalty 6. Prepayment penalty paid in a refinance
19 Qualified Mortgage Cure Provision
20 Points and Fees Cure Effective November 3, 2014 If Points and Fees exceed thresholds, still not precluded from being a QM if: The loan otherwise meets the requirements of a QM; Fees are refunded within 210 days after consummation and prior to: Any action by the member; Written notice from the consumer; or Being 60 days past due; Policies and procedures are in place for postconsummation review.
21 Points and Fees Cure Points and Fees Refund Should be an amount not less than the sum of: Dollar amounts by which the points and fees exceed the thresholds; and Interest on the dollar amount using the contract interest rate applicable during the period from consummation until the payment is made to the member.
22 HPML Escrow Requirements
23 HPML Escrow Rules Escrow Rules - TILA Effective January 1, 2015 Credit unions must establish and maintain escrow accounts for first-lien higher-priced mortgage loans for at least 5 years. Small Creditor Exemption: More than half of loans made to members in rural or underserved counties. Your credit union, together with affiliates do not originate more than 500 first lien covered transactions in the preceding calendar year. Less than $2.060bn (from $2.028bn) in assets. The credit union and affiliates cannot maintain escrows on any loans serviced.
24 Home Mortgage Disclosure Act (HMDA)
25 HMDA Thresholds Effective January 1, 2015 Asset-size exemption threshold was increased to $44 million from $43 million. Credit unions with assets of $44 million or less as of December 31, 2014 are exempt from collecting data in 2015.
26 Loan Estimate
27 Loan Estimate Disclosure Loan Estimate - replaces early TILA and GFE disclosures Timing - borrowers must receive within 3 business days of application. Business day for the Loan Estimate is a day on which the credit union s offices are open to the public for carrying out substantially all of its business functions. An application consists of the submission of: The applicant s name, income, social security number to obtain a credit report, the property address, an estimate of the value of the property; and the mortgage loan amount sought. Even if the credit union requires more information to underwrite the loan, the 3 days begins with the receipt of the above information.
28 Closing Disclosure
29 Closing Disclosure Closing Disclosure replaces final TILA and HUD-1 disclosures Timing - borrowers must receive three business days before consummation. Credit unions may estimate disclosures when actual term or cost is not reasonably available must be in good faith and due diligence used. Consummation occurs when the member becomes contractually obligated to the credit union on the loan (usually closing). Business day for purposes of the closing disclosure, means all calendar days except Sundays and the legal public holidays (5 USC 6103(a)).
30 Restriction on Fees
31 Prohibited Activities Prohibited Activities The credit union cannot impose a fee on a borrower in connection with an application for a mortgage transaction until the borrower has received the Loan Estimate and indicated an intent to proceed. Restriction on fees includes: Application fees; Appraisal fees; Underwriting fees; and Other fees imposed on the borrower. Exception for a bona fide reasonable fee for obtaining a credit report.
32 Intent to Proceed Intent to proceed when the borrower communicates that they wish to proceed after the Loan Estimate has been delivered. May include: Oral communication in person immediately upon delivery of the Loan Estimate; Oral communication over the phone, written communication via , or signing a pre-printed form after receipt of the Loan Estimate. The credit union must document the communication to satisfy record retention requirements.
33 Escrow Closing Notice
34 Escrow Closing Notice Escrow Closing Notice must be provided prior to cancelling an escrow account to any member who established an escrow account in connection with a closed-end consumer credit transaction secured by a first lien on real property. Consumer Requested Cancellation Notice must be provide no later than 3 business days before closure (closing disclosure definition). Not Consumer Requested Cancellation Notice must be received by the borrower no later than 30 business days before the closure. Exceptions to Escrow Closing Notice Requirement: Escrow account was established solely in connection with the borrower s delinquency or default. Underlying debt obligation is terminated, including repayment, refinancing, recession, and foreclosure. * Model form (H-29) in appendix H to Regulation Z.
35 Partial Payment Disclosure
36 Partial Payment Disclosure Mortgage Servicing Transfer Notice mortgage transfer notices when ownership of a mortgage loan is transferred needs to now include information related to the partial payment policy applicable to that loan. Post-consummation and required only for closed end consumer credit secured by a dwelling or real property. Partial Payment Disclosure Requirements of content in model form (H-25) in appendix H or Regulation Z.
37 Proposed Amendments to the Final Rule Integrated Mortgage Disclosures
38 The Final, Final Rule? Expect to have revisions to these rules prior to August 1, Here is what is proposed FINAL: When rate is locked, revised loan estimate must be provided no later than the three business day (as opposed to the date the rate is locked). Construction loans proposal would add a new provision allowing credit unions to include a statement on the Loan Estimate Form to preserve the ability for transactions expected to settle more than 60 days after the initial Loan Estimate, the ability to provide the borrower with a revised loan estimate.
39 Home Mortgage Disclosure Act (HMDA) Proposed Revisions
40 HMDA Proposed Revisions Reporting for all dwelling-secured loans generally (whether for home purchase, home improvement or refinancing). Loan volume reporting threshold of 25 covered loans (CUs with less not required to report). CUs reporting over 75,000 covered loans would be required to report quarterly instead of annually. Revisions to existing data points, including optional to mandatory.
41 HMDA Proposed Revisions 11 new data points: Total points and fees Prepayment penalty term Introductory interest rate Non-amortizing features Loan term Application channel Universal loan ID Loan originator number Property value Parcel number Age and Credit Score
42 Proposed Amendments to the Final Rules Mortgage Servicing
43 Proposed Revisions Mortgage Servicing Rules Comments received on or before March 15, Successor in interest All mortgage servicing rules apply to successors in interest once a servicer confirms that person s identity and ownership interest in the property; Guidance to confirm successor in interest status; Rules apply to all successors in interest who acquire an ownership interest in transfer, protected by acceleration and foreclosure.
44 Proposed Revisions Delinquency Definition added: a borrower and a borrower s mortgage loan obligation are delinquent beginning on the date a periodic payment sufficient to cover principal, interest, and, if applicable, escrow, becomes due and unpaid, until such time as the outstanding payment is made.
45 Proposed Revisions Requests for Information Amendments would change how a servicer must respond to requests for information for loans in trust where Fannie Mae or Freddie Mac is the trustee, investor or guarantor.
46 Proposed Revisions Force-placed Insurance Amendments to the required disclosures when the credit union wants to force-place when the borrower has insufficient, rather than expiring or expired, hazard insurance on the property. Other technical edits are being proposed to the model forms such as the ability to add the mortgage loan account number on the model form.
47 Proposed Revisions Early Intervention Clarification on the early intervention live contact obligations and written early intervention notice obligations. Proposal to require servicers to provide written early intervention notices to certain borrowers who are in bankruptcy or invoked cease communication rights under FDCPA.
48 Proposed Revisions Loss Mitigation Require servicers to meet the loss mitigation requirements more than once in the life of the loan (borrowers who are current after delinquency); Modify existing exception to 120 day prohibition on foreclosure filing to allow servicer to join action of senior lienholder; Clarify flexibility in setting a date to return documents and information to complete an application, must maximize borrower protections.
49 Proposed Revisions Loss Mitigation A servicer is not relieved of its obligations because the foreclosure counsel s actions or inaction caused a violation. If a complete loss mitigation is received, the servicer must promptly instruct counsel not to make a dispositive motion for foreclosure judgment or order of sale; take reasonable steps to avoid a ruling when one is pending, or delay a foreclosure sale until conditions are satisfied.
50 Proposed Revisions Loss Mitigation Written notice requirements for servicers when a complete loss mitigation application is received. Clarify how to handle information not in the borrower s control, provide written notification if third party information is missing at 30 day mark.
51 Proposed Revisions Loss Mitigation Permits short-term repayment plan based upon evaluation of an incomplete application. Servicers can stop collection documents if borrower is ineligible for that option. Clarify how loss mitigation procedures and timelines apply to a transferee servicer that receives a mortgage loan for which there is a loss mitigation application pending.
52 Proposed Revisions Prompt Payment Crediting How to treat payments for temporary loss mitigation programs or permanent loan modifications. Periodic Statements Disclosure requirements for borrowers in temporary loss mitigation programs or permanent modifications and for borrowers who have filed for bankruptcy. Exempt servicers from periodic statement for chargedoff mortgage loans if no additional fees or interest on the account will be charged and servicer provides a final periodic statement.
53 Proposed Revisions Small Servicer Exclude certain seller-financed transactions from being counted toward the 5,000 limit. Loans voluntarily serviced for a non-affiliate of the servicer. Typically the servicer would not be the creditor or assignee and therefore would not be excluded from the rule.
MANDATORY ESCROW ACCOUNTS Effective: June 1, 2013 REGULATION Requires escrow accounts be maintained for five years (rather than the current one year) for higher-priced mortgage loans. A higher-priced mortgage
Regulatory Practice Letter February 2013 RPL 13-07 High Cost Mortgages and Homeownership Counseling; Escrow Requirements - CFPB Final Rules Executive Summary The Bureau of Consumer Financial Protection
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
New Mortgage Rules Update 1 OBJECTIVES To provide information regarding the new mortgage rules, in particular: Ability-to-Repay/Qualified Mortgages; Mortgage Loan Origination Compensation; High-Cost Loans
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
TILA Escrow Requirements for High Priced Mortgage Loans (12 CFR 1026.35) The Consumer Financial Protection Bureau s (CFPB) mortgage rules include new escrow account requirements for higher-priced mortgage
Summary of the proposed changes to the Mortgage Servicing Rules The Consumer Financial Protection Bureau is proposing several amendments to the Bureau s Mortgage Servicing Rules under Regulation X, which
INFOBYTES SPECIAL ALERT: DETAILED ANALYSIS OF CFPB S FINAL ESCROW RULE FEBRUARY 15, 2013 On January 10, 2013, the Consumer Financial Protection Bureau (the Bureau ) issued its final rule (the Rule or Escrow
Overview Escrow Requirements Reg. Z High Cost Mortgage and Counseling - Reg. Z & X Ability to Repay & Qualified Mortgages Reg. Z & X Mortgage Servicing Reg. Z & X Loan Originator Compensation Reg. Z Copies
CFPB Issues Much Anticipated Final Rules: Ability to Repay, Qualified Mortgages, Escrow Requirements and Homeownership Counseling The Consumer Financial Protection Bureau ( CFPB ) issued their much anticipated
CFPB Integrated Mortgage Disclosures Today s Goal To help you not only understand the rule changes, but make sure you have the tools, resources and support to take action to implement in your credit union
Dodd Frank Mortgage Reform 2014 Business Partner Deck v1 12.16.13 Overview RULE EFFECTIVE DATE Loan Originator Compensation - TILA Loans closed and paid on or after 1/01/14 Ability to Repay/Qualified Mortgages
JANUARY 6, 2014 TILA Higher-Priced Mortgage Loans (HPML) Escrow Rule SMALL ENTITY COMPLIANCE GUIDE This guide has been updated for the following changes - the May 2013 Final Rule and October 2013 Final
STATE HIGH COST/PREDATORY LENDING REGULATIONS Updated 1/10/2014 State: Law: Cite: North Carolina NC High Cost Home Loan Law NC Rate Spread Home Loans Check both rules HB 2188 effective 10/01/2008 changes
Section 1026.43 Ability-to-Repay (ATR) 1026.43(c)(1) and Qualified Mortgage (QM) 1026.43(e), (f) Effective January 10, 2014 As of 10/15/2013- By Venessa Snell This section applies to any consumer credit
Dodd Frank Act: Mortgage Rules Karen M. Neeley 2012, Cox Smith Matthews Incorporated 1 Save the date! The following is a summary of the CFPB rules implementing Dodd Frank Act mortgage requirements. The
Regulation Z Appraisals for Higher Priced Mortgage Loans (12 CFR 1026.35 (c)) October 31, 201 3 In January 2013, the Consumer Financial Protection Bureau and the federal financial institution regulators
MAY 2, 2013 2013 Home Ownership and Equity Protection Act (HOEPA) Rule SMALL ENTITY COMPLIANCE GUIDE The Bureau recently finalized changes to this rule. The revisions amend the final rule issued January
6. In Supplement I to Part 1026 Official Interpretations: A. Under Section 1026.25 Record Retention: i. Under 25(a) General rule, paragraph 2 is revised. ii. 25(c) Records related to certain requirements
February 12, 2013 Summary of Mortgage Servicing Rules The Consumer Financial Protection Bureau (CFPB) released its final rules on mortgage loan servicing on January 17, 2013. These new national standards
The Ability to Repay (ATR)/Qualified Mortgages (QM) provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act require lenders to make a reasonable, good faith determination of a borrower
Federal Banking Law Reporter Regulations, Regulation, 12 CFR 1026.35, Requirements for higher-priced mortgage loans. Click to open document in a browser The following text of Section 1026.35 is effective
High-Cost, Higher-Priced What s the Difference? Comparison of the Similarities and Differences of Terms in Regulation Z Regulation Z uses the terms high-cost mortgage, higher-priced mortgage and higher-priced
National Banker Call Loan Originator Compensation and HOEPA Final Rules Thursday, June 6, 2013 The information contained in this presentation is for informational purposes only and is provided as a public
1 FEBRUARY 4, 2013 CFPB issues ability-to-repay and qualified mortgage rules By Raymond J. Gustini, Lloyd H. Spencer, Tiana M. Butcher, Courtney L. Lindsay II, and Pierce Han No standard is perfect, but
The New Mortgage Lending Process: A 2014 Check-Up and 2015 Planning Copyright 2012 Tata Consultancy Services Limited No Legal Advice, Opinions, or Services Provided This presentation does not constitute
Dodd Frank Act Mortgage Rules FAQs Qualified Mortgage (QM) Criteria 3% Fee Cap What goes in to the calculation of fees? The same test is used for HOEPA and for QM. It includes everything that goes in to
The 4 CFPB Final Rules of the Dodd-Frank Wall Street Reform and Consumer Protection Act December 2013 Agenda 1. LO Compensation 2. ATR / QM / TQM 3. ECOA & HPML 4. HOEPA & Home Counseling Agenda In the
CFPB Regulations on Ability to Repay and Qualified Mortgages MDDCCUA Training October 30, 2013 E. Andrew Keeney, Esq. Kaufman & Canoles, P.C. Ability-to-Repay and Qualified Mortgage Rules E. Andrew Keeney,
RPL Number 10-17 Financial Services Regulatory Practice Regulatory Practice Letter ADVISORY Amendments to Mortgage Loan Provisions under Regulation Z Executive Summary The Federal Reserve Board ( Fed )
COMMUNICATION NO. 313635 PROPOSED ORDINANCE AMENDMENT Sponsored by THE HONORABLE TONI PRECKWINKLE, PRESIDENT, EARLEAN COLLINS, JERRY BUTLER, JOHN P. DALEY, JESUS G. GARCIA, EDWIN REYES, ROBERT B. STEELE
TILA-RESPA Integrated Disclosure Rule * January 21, 2015 Presented by David Kantor Stinson Leonard Street LLP David.email@example.com 612-335-1620 1. Effective Date. The new Integrated Disclosures
24-1.1E. Restrictions and limitations on high-cost home loans. (a) Definitions. The following definitions apply for the purposes of this section: (1) "Affiliate" means any company that controls, is controlled
Single-Family Legal Essentials: CFPB Rules Part 1 2 Introduction & Background Dodd-Frank Act Rulemaking Mandate Established CFPB and transferred authority over TILA, RESPA, and other consumer financial
QM - Qualified Mortgages Internal Training Use only July 1, 2014 #T014 Rules & Terms to Know QM ATR HPML High Cost Rebuttable Presumption Safe Harbor Excludable Discount Pts History of QM & ATR Rules The
CFPB Mortgage Servicing Rules Overview For additional information, visit www.consumerfinance.gov/regulations Note: This document was used in support of a live discussion. As such, it does not necessarily
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.
Ability to Repay/Qualified Mortgage Rule Note: This document was used in support of a live discussion. As such, it does not necessarily express the entirety of that discussion nor the relative emphasis
GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 2009 SESSION LAW 2009-457 HOUSE BILL 1222 AN ACT TO UPDATE THE RATE SPREAD AND HIGH-COST HOME LOANS STATUTES, AND TO MAKE A CONFORMING CHANGE TO THE EMERGENCY
Seeded and Actual Questions from our Dodd Frank Act Mortgage Regulations Implementation Workshops Fort Walton Beach, Orlando, and Tampa September 2013 Ability to Repay Lending Questions 1. We are not sure
TILA Higher Priced Mortgage Loans Appraisal Rule Promote the informed use of consumer credit by requiring disclosures about its costs and terms Purpose of the TILA HPML Appraisal Rule: Congress enacted
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.
A DV I S O RY April 2013 The CFPB Finalizes New Mortgage Servicing Rules On January 17, 2013, the Consumer Financial Protection Bureau (CFPB) finalized rules implementing the mortgage loan servicing requirements
CLIENT AND FRIENDS BANKING UPDATE SILVER, FREEDMAN & TAFF, L.L.P. 3299 K STREET, N.W., SUITE 100, WASHINGTON, D.C. 20007 (202) 295-4500 (202) 337-5502 www.sftlaw.com A DETAILED SUMMARY OF THE CFPB S FINAL
Office of Consumer Protection Truth-In-Lending Real Estate Settlement Procedures Act Integrated Disclosures Webinar February 11, 2015 The information contained in this presentation is for informational
ECOA & TILA APPRAISAL RULES Appraisal Customer Access Issues Managing the Dodd-Frank Act Appraisal Process Who owns the appraisal or valuation? For which party or parties is the appraisal performed? Patti
Community Bank Audit Group Dodd-Frank Lending Issues June 2, 2014 by: Stephen King, JD, AMLP MEMBER OF PKF NORTH AMERICA, AN ASSOCIATION OF LEGALLY INDEPENDENT FIRMS 2013 Wolf & Company, P.C. Today s Agenda
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
Regulatory Practice Letter September 2012 RPL 12-17 Mortgage Servicing Standards - CFPB Proposed Rule Executive Summary The Bureau of Consumer Financial Protection ( CFBP or Bureau ) released two proposed
Changes in Mortgage Regulation in 2013 Katie Wechsler December, 2012 In 2011 and 2012 the Federal banking agencies proposed several regulations to the mortgage industry, none of which have been finalized,
Congressional Concerns Ability to Repay and Qualified Mortgage TILA 129 C February 2014 Patti Blenden Financial Solutions 2 The Dodd Frank Act (DFA) changes reflect 3 primary concerns with the mortgage
Outlook Live Webinar- June 17, 2014 TILA-RESPA Integrated Disclosures Presented by the Consumer Financial Protection Bureau Visit us at www.consumercomplianceoutlook.org Disclaimer The Bureau issued the
A DV I S O RY July 2012 On July 9, 2012, the Bureau of Consumer Financial Protection (CFPB) issued a proposed rule on mortgage disclosures (Proposed Rule) implementing requirements of the Dodd-Frank Wall
EXPLOSION OF NEW MORTGAGE REGULATION ABILITY TO REPAY/QUALIFIED MORTGAGE RULE Mortgage Regulation Teleseminar Series January 24, 2013 FINANCIAL SERVICES REGULATORY GROUP Leonard A. Bernstein firstname.lastname@example.org
360.100 Predatory lending -- Definitions -- Limitations on high-cost home loans -- Conditions -- Penalties. (1) The following definitions apply for the purposes of this section: (a) "High-cost home loan"
December 21, 2012 MEMORANDUM TO: The Board of Directors FROM: SUBJECT: Sandra L. Thompson Director ~w Division of Risk Management Supervision 1 / 4 Mark E. arce j1 Director Division of Depo or and Corsurner
Wall Street Reform and Consumer Financial Protection Act of 2010 Mortgage Servicing Issues February 4, 2011 Presented by Joseph Gabai 2010 Morrison & Foerster LLP All Rights Reserved mofo.com Financial
REGULATORY ALERT NATIONAL CREDIT UNION ADMINISTRATION 1775 DUKE STREET, ALEXANDRIA, VA 22314 DATE: January 2014 NO.: 14-RA-04 TO: SUBJECT: ENCL: Federally Insured Credit Unions Mortgage Servicing Requirements
DECEMBER 18, 2013 Help For Struggling Borrowers A guide to the mortgage servicing rules effective on January 10, 2014 Table of contents Introduction... 7 1. Applying for loss mitigation... 10 1.1 Introduction...
Ability to Repay & QM Regulations 2013 Rushmore Loan Management Services LLC. All Rights Reserved. This is intended as educational material only. It does not provide legal advice. Revised December 2013
5/15/ New Loan Origination and Mortgage Servicing Rules Personal Finance Seminar for Professionals University of Maryland Extension Presenter: Diane Cipollone, Esq. Director of Training National Fair Housing
This summary is provided by the Minnesota Credit Union Network for informational purposes only, and is intended to provide credit unions with the general regulatory requirements and effective dates for
August 2012 CFPB Proposes Comprehensive Mortgage Servicing Regulations On August 9, 2012, the Consumer Financial Protection Bureau (CFPB) issued two notices of proposed rulemaking (NPRs) 1 implementing
WWW.ALSTON.COM Financial Services & Products ADVISORY DECEMBER 19, 2014 CFPB s Proposed Changes to the Mortgage Servicing Rules: The Devil Is in the Details On November 20, 2014, the Consumer Financial
............................................................................................. Overview of the TILA-RESPA Rule.............................................................................................
TILA/RESPA Integrated Disclosures BRIAN A. NETTLEINGHAM Attorney/Shareholder Regulatory Compliance Group BACKGROUND Dodd-Frank Wall Street Reform Act Created the Consumer Financial Protection Bureau National
TILA-RESPA Integrated Disclosure Rule May 13, 2015 Joseph J. Reilly Partner Benjamin K. Olson Partner 1 Key Changes Effective for applications received by the creditor or mortgage broker on or after August
Regulation X Real Estate Settlement Procedures Act The Real Estate Settlement Procedures Act of 1974 () (12 U.S.C. 2601 et seq.) (the Act) became effective on June 20, 1975. The Act requires lenders, mortgage
OVERVIEW TRUTH-IN-LENDING/REGULATION Z POLICY ABILITY TO REPAY (APPENDIX Q UNDERWRITING GUIDELINES) AND QUALIFIED MORTGAGE PROTECTIONS The Truth-In-Lending Act (TILA), in addition to requiring extensive
Review of FHA s Policies January 16, 2014 Presented by Arlene Nunes 1 Agenda HUD s Qualified Mortgage Rule 2014 FHA Loan Limits (ML 2013 43) Manual Underwriting Final Notice Single Family Housing Policy
TILA RESPA Integrated Disclosures The Loan Estimate and Miscellaneous Requirements Lynne Murphy Breen, Esquire Sue Ellen Rogal, Esquire September 16, 2015 On October 3 rd, life as we know it will change
PLEASE NOTE: In most BUT NOT ALL instances, the page and line numbering of bills on this web site correspond to the page and line numbering of the official printed version of the bills. REFERENCE TITLE: