Update on High Cost Mortgages & Homeownership Counseling

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1 Tuesday Nvember 26, p.m. Central Time Update n High Cst Mrtgages & Hmewnership Cunseling Billy Seitz Senir Managing Cnsultant BKD, LLP Michael Prince Senir Cnsultant BKD, LLP TO RECEIVE CPE CREDIT Participate in entire webinar Answer plls when they are prvided If yu are viewing this webinar in a grup Cmplete grup attendance frm with Title & date f live webinar Yur cmpany name Yur printed name, signature & address All grup attendance sheets must be submitted t within 24 hurs f live webinar Answer plls when they are prvided If all eligibility requirements are met, each participant will be ed their CPE certificates within 15 business days f live webinar 2 // experience access 1

2 BACKGROUND OF REVISIONS 2010 Ddd-Frank Wall Street Refrm & Cnsumer Prtectin Act (DFA) added cnsumer prtectins regarding New requirement fr prviding List f Hmewnership Cunseling Organizatins (Reg X) Expanded cverage f Hme Ownership & Equity Prtectin Act (Reg Z) aka HOEPA Lans, Sectin 32 Lans r High Cst Mrtgages referred t as HOEPA lans/lines in this presentatin Amended HOEPA cverage tests (Reg Z) Expanded restrictins n HOEPA lans/lines New requirement cnsumers receive hmewnership cunseling befre btaining a HOEPA lan/line (Reg Z) 3// experience access BACKGROUND OF REVISIONS Applies t cnsumer purpse clsed-end & pen-end lans/lines secured by cnsumer s principal dwelling. Exemptins include Reverse mrtgages Initial cnstructin lans Lans riginated & directly financed by FHA Lans riginated & directly financed by USDA under Sectin 502 Direct Lan Prgram Cnsumer Financial Prtectin Bureau s (CFPB) final rule fr HOEPA & Hmewnership Cunseling is effective January 10, // experience access 2

3 REGULATION X - LIST OF HOMEOWNERSHIP COUNSELING ORGANIZATIONS Applies t ALL cnsumer purpse clsed-end & pen-end lans/lines secured by cnsumer s principal dwelling A lender, mrtgage brker, r dealer wh receives an applicatin r infrmatin sufficient t cmplete an applicatin shall prvide list within three business days f applicatin Fr HELOCs, it must be prvided at time f applicatin List prvided must cntain relevant cunseling rganizatins that prvide cunseling services in applicant s lcatin & shall be btained n earlier than 30 days prir t the time list is prvided t applicants. CFPB website: 5 // experience access REGULATION X - LIST OF HOMEOWNERSHIP COUNSELING ORGANIZATIONS 6 // experience access 3

4 REGULATION X - LIST OF HOMEOWNERSHIP COUNSELING ORGANIZATIONS 7 // experience access REGULATION X - LIST OF HOMEOWNERSHIP COUNSELING ORGANIZATIONS Unless prhibited by Regulatin Z, list can be cmbined & prvided with ther Regulatin Z required disclsures Mrtgage brkers r dealers can prvide list n behalf f a lender, but lender must ensure list is prvided It can be mailed t each applicant r delivered via ther means, if prvided electrnically ESIGN Act prvisins apply In the event f adverse actin r withdrawal befre three business days expires, list des nt have t be prvided If multiple lenders are invlved, nly ne list has t be prvided If a request has multiple applicants, nly ne list has t be prvided 8 // experience access 4

5 EXPANDED HOEPA COVERAGE Applies t Includes New HOEPA Applicability Principal dwellings Purchase-mney, Refinances, & Open-end credit (HELOCs) Applies if APR exceeds Average Prime Offer Rate (APOR) by: 1 st Liens >6.5 percentage pints 1 st Liens less than $50K & secured by persnal prperty (i.e. manufactured hme) >8.5 percentage pints Subrdinate-Liens >8.5 percentage pints OR Applies if ttal pints & fees exceed Nte Amunt Fee Trigger: $20K* 5% f ttal lan amunt Nte Amunt Fee Trigger: $19,999.99* Lesser f 8% f ttal lan amunt r $1,000* OR Prepayment Trigger** Prepayment penalty after 36 mnths r exceeds mre than 2% f amunt prepaid 9// experience access 9 // experience access DETERMINATION OF APR FOR HOEPA COVERAGE Fixed / Variable: Index / Nn-Index: APR Determinatin: Fixed Rate Lan/Line Variable Rate Lan/Line Variable Rate Lan/Line Nt Applicable Index Based Nn-Index Based Use the interest rate in effect as f the date the interest rate was set t calculate the APR Use the interest rate resulting frm adding the maximum margin permitted t the value f the index rate in effect as f the date the interest rate was set OR the intrductry rate; whichever is higher, t calculate the APR Use the maximum interest rate that may be impsed during the term f the lan / plan t calculate the APR 10 // experience access 5

6 POINTS & FEES CALCULATION FOR HOEPA COVERAGE - CLOSED-END FINANCE CHARGES Includes fees/charges knwn at r befre cnsummatin 1) Finance Charges Pints & fees include all items in the finance charge (1026.4(a) & (b)) except the fllwing a) Interest r time price differential b) Mrtgage insurance premiums (MIPs) impsed fr gvernment agency prgrams (including annual FHA premiums, VA funding fees, & USDA guarantee fees) c) Private Mrtgage Insurance - entire amunt f premiums r charges payable after cnsummatin fr nn-gvernment impsed mrtgage insurance prgrams OR if payable at r befre cnsummatin, prvided 1. Nt in excess f 2.75% f riginal insured principal bligatin fr first-time hmebuyers wh have cmpleted hmewnership cunseling OR 2. Nt in excess 3% f riginal insured principal bligatin fr all thers (Natinal Husing Act 12 USC 1709(c)(2)(A)) 3. Additinally, a cnditin f mrtgage insurance is premiums r charges are required t be refundable n a pr rata basis & refund is t be issued upn ntificatin f satisfactin f underlying mrtgage lan 11 // experience access POINTS & FEES CALCULATION FOR HOEPA COVERAGE - CLOSED-END FINANCE CHARGES Finance Charges excluded frm Pints & Fees calculatin d) Any Bna fide third-party charge nt retained by the creditr, lan riginatr, r an affiliate f either e) Up t 2 bna fide* discunt pints paid by the cnsumer if the interest rate withut the discunt des nt exceed 1. APOR by mre than 1 percentage pint OR 2. Fr transactins invlving persnal prperty (i.e. manufactured hme) cmpare t the average rate fr a lan insured under Title I f the Natinal Husing Act by mre than 1 percentage pint f) Up t 1 bna fide* discunt pint paid by the cnsumer if the interest rate withut the discunt des nt exceed 1. APOR by mre than 2 percentage pints r 2. Fr transactins invlving persnal prperty (i.e. manufactured hme), cmpare t the average rate fr a lan insured under Title I f the Natinal Husing Act by mre than 2 percentage pints *Discunt pint is bna fide if it reduces the cnsumer s interest rate by an amunt reflecting industry practices, such as secndary market nrms. 12 // experience access 6

7 POINTS & FEES CALCULATION FOR HOEPA COVERAGE - CLOSED-END COMPENSATION 2) Pints & fees include: all cmpensatin paid directly r indirectly by a cnsumer r creditr t a lan riginatr that can be attributable t that transactin*, except cmpensatin paid By a cnsumer t a mrtgage brker that has already been included as a finance charge under (a) & (b) By a mrtgage brker t a lan riginatr that is an emplyee f brker By a creditr t a lan riginatr that is an emplyee f creditr By a retailer f manufactured hmes t its emplyees Hwever, if a manufactured hme retailer qualifies as a lan riginatr under (a)(1), then cmpensatin paid by a cnsumer/creditr t retailer fr cnducting lan riginatr activities that can be attributable t that transactin at the time the interest rate is set MUST be included *Timing The amunt f cmpensatin is determined as f the date the interest rate is set, regardless f whether the cmpensatin is paid befre, at, r after cnsummatin. 13 // experience access POINTS & FEES CALCULATION FOR HOEPA COVERAGE - CLOSED-END REAL ESTATE RELATED FEES 3) Pints & fees include all items listed in (c)(7) (ther than amunts held fr future payment f taxes), unless The charge is reasnable The creditr receives n direct r indirect cmpensatin in cnnectin with the charge & The charge is nt paid t an affiliate f the creditr Nte: If ne r mre f these cnditins are nt met, INCLUDE these charges in pints & fees Example: a reasnable fee paid by a cnsumer t an independent third-party appraiser may be excluded in pints & fees calculatin (assumes creditr nr affiliate retains any prtin f fee) Example: a reasnable fee paid by a cnsumer t creditr s affiliated title cmpany fr title insurance wuld be included in pints & fees calculatin 14 // experience access 7

8 POINTS & FEES CALCULATION FOR HOEPA COVERAGE - CLOSED-END CREDIT INSURANCE PREMIUMS 4) Pints & fees include premiums r ther charges payable at r befre cnsummatin fr any credit life, credit disability, credit unemplyment, credit prperty, r any ther life, accident, health, r lss f incme insurance fr which the creditr is beneficiary This als includes any payments directly r indirectly fr any debt cancellatin r suspensin agreement r cntract Included even if rlled int lan amunt Nte: Credit prperty insurance is insurance which prtects creditr's interest in the prperty. It des nt include hmewner s insurance which prtects cnsumer 15// experience access POINTS & FEES CALCULATION FOR HOEPA COVERAGE - CLOSED-END MAXIMUM PREPAYMENT PENALTY 5) Pints & fees include the maximum prepayment penalty that may be charged r cllected under the terms f the mrtgage lan Prepayment penalty means a charge impsed fr paying all r part f the transactin s principal befre the date n which the principal is due, ther than a waived, bna fide third-party charge the creditr impses if the cnsumer prepays all f the transactin s principal sner than 36 mnths after cnsummatin, prvided, hwever, interest charged cnsistent with the mnthly interest accrual amrtizatin methd is nt a prepayment penalty fr extensins f credit insured by the Federal Husing Administratin cnsummated befre January 21, ) Prepayment paid in refinance Pints & fees includes the ttal prepayment penalty incurred by the cnsumer if the cnsumer refinances the existing mrtgage lan with the current hlder f the existing lan, a servicer acting n behalf f the current hlder, r an affiliate f either. 16 // experience access 8

9 POINTS & FEES HOEPA COVERAGE - OPEN-END CREDIT All items in previus slides fr Clsed-End lans, plus 7) any fees charged fr participatin in an pen-end credit plan payable at r befre accunt pening (whether assessed n an annual r ther peridic basis) 8) any transactin fee, including any minimum fee r pertransactin fee, that will be charged fr a draw n the credit line, where the creditr must assume that the cnsumer will make at least ne draw during the term 17 // experience access POINTS & FEES HOEPA COVERAGE - OPEN-END CREDIT MAXIMUM PREPAYMENT PENALTY There are nly slight differences fr the inclusin f prepayment penalty in pints & fees in an pen-end credit transactin fr determinatin f HOEPA cverage as fllws The maximum prepayment penalty that may be charged r cllected under the terms f the pen-end credit plan is defined as fllws Prepayment penalty means, a charge impsed by the creditr if the cnsumer terminates the pen-end credit plan prir t the end f its term, ther than a waived bna fide third-party charge the creditr impses if the cnsumer terminates the pen-end credit plan sner than 36 mnths after accunt pening. The ttal prepayment penalty [as defined abve] incurred by the cnsumer if the cnsumer refinances an existing clsed-end credit transactin with an pen-end credit plan, r terminates an existing penend credit plan in cnnectin with btaining a new clsed r pen-end credit transactin with the current hlder f the existing plan, servicer acting n behalf f the current hlder, r an affiliate f either. 18 // experience access 9

10 CALCULATING TOTAL LOAN AMOUNT FOR HOEPA COVERAGE Steps t Calculate: Step 1: Start with Principal Lan Amunt Step 2: Add all fees & charges financed by the creditr & are nt part f the finance charge Calculating Ttal Lan Amunt fr Pints/Fees Principal Lan Amunt (+) Any ther amunts financed by creditr nt part f finance charge Step 3: Subtract prepaid finance charges Step 4: Subtract (c)(7) items if they are cnsidered pints & fees under (b)(1) & are financed by the creditr unless the creditr/affiliate charges the fees Step 5: Subtract premiums/charges fr insurances listed that are bth financed by creditr & included in pints & fees under (b)(1) Step 6: Subtract prepayment penalty if cnsumer refinances with creditr, servicer, r affiliate f either that are bth financed by creditr & included in pints & fees under (b)(1) Refer t Sectin (b)(4) f Regulatin Z (-) Prepaid Finance Charges (-) Real Estate Related Fees Excluded under (c)(7)- that are bth cnsidered pints/fees & are financed by the creditr, unless creditr r affiliate receives cmpensatin fr the charge (-) Premiums/charges fr life, accident, health, r ther lssf-incme insurance payable at/befre clsing that are bth cnsidered pints/fees & are financed by the creditr (-) Ttal prepayment penalty charged if cnsumer refinances with creditr, servicer, r affiliate f either that are bth cnsidered pints/fees & are financed by the creditr 19 // experience access HELOC ILLUSTRATIVE EXAMPLE Lan Terms: Credit Limit: $10, Lien Psitin: 2 nd Psitin Rate: 5 Yr. Draw Perid / Variable WSJ Prime + 1% Margin / 2% Intrductry Rate fr 3 m. Fees charged: $400 appraisal, $25 credit reprt, $16 fld determinatin (all 3 rd party/nt retained), $300 dc prep, $250 title fees (charged by affiliate), $100 annual/participatin fee, $0 per-draw fee (we must assume ne draw if a fee was charged) Rate Lcked: 01/20/2014 APOR n 01/20/2014: 2.93% WSJ-Prime n 01/20/2014: 3.25% APR Test: Pints/Fees Test: Prepayment Penalty: Margin (1%) + Index at time f rate lck (3.25%) = 4.25% Since this is a 2 nd psitin lien, we cannt exceed 11.43% APR (which is mre than 8.5 percentage pints abve APOR) Ttal Lan Amunt (TLA): $10,000 $650 / $10,000 = r 6.50%, which is less than 8% f TLA; $650 was lwer than $1,000 Penalty $200 r charged 36 mnths 20 // experience access 10

11 HELOC ILLUSTRATIVE EXAMPLE 21 // experience access REQUIRED DISCLOSURE FOR HOEPA LOANS/LINES All HOEPA lans/lines must receive a disclsure cntaining the fllwing at least three business days prir t cnsummatin: 1) Ntice: Yu are nt required t cmplete this agreement merely because yu have received these disclsures r have signed a lan applicatin. If yu btain this lan, the lender will have a mrtgage n yur hme. Yu culd lse yur hme, & any mney yu have put int it, if yu d nt meet yur bligatins under the lan. 2) Annual percentage rate 3) Regular payment; minimum peridic payment example; balln payment Fr clsed-end credit amunt f regular mnthly payment (r ther peridic payment, if applicable) amunt f any balln payment if allwed under (d)(1) 22 // experience access 11

12 REQUIRED DISCLOSURE FOR HOEPA LOANS/LINES (CONTINUED) 4) Variable-rate - if lan has a variable rate, a statement the interest rate & mnthly payment may increase & the amunt f the single maximum mnthly payment based n the maximum interest rate [what the rate ceiling will be ver the term f the bligatin] 5) Amunt brrwed r credit limit Clsed end face amunt f nte Open end Credit limit f plan 23// experience access LIMITATIONS FOR HOEPA LOANS/LINES A HOEPA lan/line shall nt include the fllwing A balln payment (which is a payment mre than 2x the nrmal peridic payment) ( (d)(1)) unless it meets ne f the fllwing three criteria 1. The payment schedule is adjusted t accmmdate the cnsumer s seasnal r irregular incme 2. The lan is a bridge lan with a term 12 mnths OR 3. The creditr meets the criteria fr serving predminantly rural r underserved area OR meets the small creditr definitin (sunset 1/10/2016), & the lan meets specific criteria set frth in the Bureau s Ability-t-Repay/Qualified Mrtgage Rule. ( (d)(1)(C) & (f)) Negative amrtizatin - a payment schedule with regular peridic payments causing principal balance t increase Advance payments - a payment schedule cnslidating mre than tw peridic payments & pays them in advance frm prceeds Increased interest rate - an increase in interest rate after default 24 // experience access 12

13 LIMITATIONS FOR HOEPA LOANS/LINES A HOEPA lan/line shall nt include the fllwing Rebates- fr rebates f interest arising frm a lan acceleratin due t default that is less favrable than the actuarial methd f the Husing & Cmmunity Develpment Act f 1992 Prepayment penalty - a prepayment penalty as fllws Clsed-end credit - a charge impsed fr paying all r part f the transactin s principal befre the date n which the principal is due, ther than a waived, bna fide third-party charge the creditr impses if the cnsumer prepays all f the transactin s principal sner than 36 mnths after cnsummatin, prvided, interest charged cnsistent with the mnthly interest accrual amrtizatin methd is nt a prepayment penalty fr extensins f credit insured by the Federal Husing Administratin cnsummated befre January 21, 2015 Open-end credit - a charge impsed by the creditr if the cnsumer terminates the pen-end credit plan prir t the end f its term, ther than a waived bna fide third-party charge the creditr impses if the cnsumer terminates the pen-end credit plan sner than 36 mnths after accunt pening 25 // experience access LIMITATIONS FOR HOEPA LOANS/LINES A HOEPA lan/line shall nt include the fllwing Acceleratin f debt - a demand feature permitting the creditr t accelerate the indebtedness by terminating the HOEPA lan/line mrtgage in advance f the riginal maturity unless There is fraud / misrepresentatin by the cnsumer The cnsumer fails t meet repayment terms fr any utstanding balance resulting in a default Any actin r inactin by the cnsumer adversely affecting the creditr's security fr the lan 26// experience access 13

14 PROHIBITED ACTS OR PRACTICES FOR HOEPA LOANS/LINES ( ) Prhibited Acts / Practices fr HOEPA Lans/Lines 1) Hme-imprvement cntracts - creditr shall nt pay a cntractr frm the prceeds f a HOEPA lan/line ther than By instrument (i.e. check) payable t the cnsumer r jintly t bth cnsumer & cntractr OR At the electin f the cnsumer, thrugh a third-party escrw agent pursuant t a written agreement signed by the cnsumer, creditr, & cntractr prir t any disbursements 2) Ntice t assignee - The fllwing ntice must be prvided t purchaser r assignee: Ntice: This is a mrtgage subject t special rules under the Federal Truth in Lending Act. Purchasers r assignees f this mrtgage culd be liable fr all claims & defenses with respect t the mrtgage that the cnsumer culd assert against the creditr. 27 // experience access PROHIBITED ACTS OR PRACTICES FOR HOEPA LOANS/LINES 3) Refinancing within ne-year a creditr shall nt refinance any HOEPA lan/line t the same cnsumer int anther HOEPA lan/line within a year f riginatin, unless the refinance is in the cnsumer s interest An assignee hlding r servicing a HOEPA lan/line shall nt refinance a HOEPA lan/line fr the remainder f the ne-year perid frm the date f riginatin, unless the refinance is in the cnsumer s interest Creditrs & assignees are prhibited frm engaging in acts r practices t evade the refinance prvisins including patterns f arranging fr the refinancing f its wn lans by affiliated r unaffiliated creditrs 28// experience access 14

15 PROHIBITED ACTS OR PRACTICES FOR HOEPA LOANS/LINES 4) Repayment ability Clsed-end: except fr bridge lans a creditr must cmply with requirements under (the Ability t Repay rules) t cmply with the repayment ability prvisins f high-cst, clsed-end mrtgages Open-end: Similarly t clsed-end, a creditr must cnsider expected incme r assets (verified with W-2s, tax returns, payrll receipts, financial institutin recrds, r ther third party dcuments that prvide reasnably reliable evidence); & current bligatins, including any mrtgage-related bligatins such as prperty taxes, required insurance premiums, cmmunity assciatin fees, grund rent, & leasehld payments A presumptin f cmpliance is prvided if these standards are met 29 // experience access PROHIBITED ACTS OR PRACTICES FOR HOEPA LOANS/LINES 5) Presumptin f Cmpliance fr HOEPA line f credit If the creditr determined the cnsumer s ability t repay the bligatin pursuant t (a)(4)(ii) [referenced previusly] If the creditr uses the largest required minimum peridic payment based n the full extensin f the credit limit with n additinal extensins thereafter where the cnsumer makes nly the required minimum peridic payment during draw perid & any repayment perid, &, if the rate is variable, uses the maximum APR designated in the cntract at the time f accunt pening & at any repayment perid Takes int accunt ne f the fllwing 1. Debt t incme rati which includes current bligatins & mrtgagerelated bligatins required by anther creditr undertaken prir t r at accunt pening & secured t the same dwelling as the transactin OR 2. The incme the cnsumer will have after paying current bligatins Refer t Sectin (a)(4) f Regulatin Z & its Official Cmmentary fr further details 30// experience access 15

16 PROHIBITED ACTS OR PRACTICES FOR HOEPA LOANS/LINES 6) Pre-lan cunseling - a creditr is prhibited frm extending a HOEPA lan/line t a cnsumer unless the creditr receives a written certificatin the cnsumer has btained cunseling n the advisability f the mrtgage frm a cunselr wh is apprved by the Secretary f the US Dept. f HUD r, if permitted by the Secretary, a State husing authrity. Certain timing, affiliatin restrictins, & cntent requirements apply. Refer t Sectin (a)(5) f Regulatin Z 7) Recmmend default - creditrs & mrtgage brkers cannt recmmend r encurage default n an existing lan r ther debt prir t & in cnnectin with the cnsummatin r accunt pening f a HOEPA lan/line that refinances all r any prtin f such existing lan r debt 31 // experience access PROHIBITED ACTS OR PRACTICES FOR HOEPA LOANS/LINES 8) Mdificatin/Deferral fees - a creditr, successr-in-interest, assignee, r any agent f such party may nt charge a cnsumer any fee t mdify, renew, extend r amend a HOEPA lan/line, r t defer any payment due under the terms f the mrtgage 9) Late fees - any late payment charge impsed in cnnectin with a HOEPA lan/line must be specifically permitted by the terms f the lan cntract r pen-end agreement & cannt exceed 4% f the amunt f the payment past due Timing - a late payment charge may be impsed nly if the payment was nt received by the end f the 15-day perid beginning n the date the payment is due; r if the interest is paid in advance, the end f the 30-day perid beginning n the date the payment is due Multiple late charges - late payments may nt be impsed if any delinquency is attributable nly t a late payment charge impsed n an earlier late payment & the payment is therwise a full payment fr the perid if paid by due date r within grace perid Failure t make required payment - if terms f the lan cntract r pen-end agreement prvide, a creditr can apply payments received first t past due balances & impse late charges until the accunt is brught current when the cnsumer fails t make ne r mre payments & upn resuming payments des nt bring the accunt current 32 // experience access 16

17 PROHIBITED ACTS OR PRACTICES FOR HOEPA LOANS/LINES (CONTINUED) 10) Payff statements - generally a creditr r servicer is prhibited frm charging a fee fr prviding a cnsumer (r authrized persn) t btain a payff statement f the utstanding balance Prcessing Fee - It is permissible fr a creditr r servicer t charge a prcessing fee t cver the cst f prvide a payff statement by fax r curier as lng as the fee des nt exceed cmparable fees fr similar services n nn HOEPA lans/lines Prcessing fee disclsure - befre charging a prcessing fee fr a payff statement delivered by fax r curier, the creditr r servicer must disclse t cnsumer r authrized persn that payff statements are available thrugh ther means withut a charge Multiple payff statement requests - creditr r servicer can charge a cnsumer r authrized persn a fee fr prviding the payff statement if cnsumer r authrized persns has btained 4 such statements in a calendar year; in a subsequent calendar years the limitatins abve apply & the cunt resets Delivery - Payff statements must be prvided t the cnsumer r authrized persn within 5 business days after receiving the request 33 // experience access PROHIBITED ACTS OR PRACTICES FOR HOEPA LOANS/LINES (CONTINUED) 11) Financing pints & fees - creditrs are prhibited frm financing charges cnsidered pints & fees under (b)(1) & (b)(2) Charges excluded frm the definitin f pints & fees, such as bna fide third-party charges can be financed. See slide 7 Credit insurance premiums r debt cancellatin r suspensin fees shall nt be cnsidered financed by the creditr if they are calculated & paid in full n a mnthly basis Prhibited Structuring fr Evasin Structuring lans t evade requirements fr HOEPA lans/lines, including dividing lans int separate parts, is nt allwed 34 // experience access 17

18 NEXT STEPS Establish prcedures fr prviding Hmewnership Cunseling Organizatin list within three business days f applicatin (fr HELOCs-at applicatin) Analysis f current lan prducts & HELOCS t determine impact (i.e. Will yur bank have any HOEPA lans/lines?) Establish prcedures fr prviding required HOEPA disclsures, as necessary, at least three business days prir t cnsummatin Adpt required plicies & prcedures Train emplyees 35 // experience access RESOURCES Final Rule Resurces January 31, 2013: July 10, 2013 (Amendments): September 13, 2013 (Amendments): Octber 15, 2013 (Interim Final Rule): mrtgage-rules-under-the-real-estate-settlement-prcedures-act-regulatin-x Small Entity Cmpliance Guide Regulatin Z (HOEPA): Regulatin Z & X (Servicing Rules): 36 // experience access 18

19 Questins? Thank Yu! 19

20 CONTINUING PROFESSIONAL EDUCATION (CPE) CREDITS BKD, LLP is registered with the Natinal Assciatin f State Bards f Accuntancy (NASBA) as a spnsr f cntinuing prfessinal educatin n the Natinal Registry f CPE Spnsrs. State bards f accuntancy have final authrity n the acceptance f individual curses fr CPE credit. Cmplaints regarding registered spnsrs may be submitted t the Natinal Registry f CPE Spnsrs thrugh its website: The infrmatin in BKD webinars is presented by BKD prfessinals, but applying specific infrmatin t yur situatin requires careful cnsideratin f facts & circumstances. Cnsult yur BKD advisr befre acting n any matters cvered in these webinars. 39 // experience access CPE CREDIT Up t 1 CPE credit will be awarded upn verificatin f participant attendance; hwever, credits may vary depending n state guidelines Fr questins, cncerns r cmments regarding CPE credit, please BKD Learning & Develpment Department at 40 // experience access 20

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