Update on High Cost Mortgages & Homeownership Counseling
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- Maximilian Gaines
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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 bseitz@bkd.cm Michael Prince Senir Cnsultant BKD, LLP mprince@bkd.cm 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 training@bkd.cm 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 training@bkd.cm 40 // experience access 20
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