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Regulation Z High Priced Loan Definition Change Proposal

This proposal will make several big changes to Regulation Z /TILA. You can find the text in the federal register at: 75 FR 58539. The comment period closed 12/23/10 and we are awaiting more information from the Federal Reserve Board on whether all or part of this rule will move forward. Here is a summary of the key parts of the proposal: Rescission: There is a proposed new ‘Notice of...
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Anti Money Laundering (AML) and Suspicious Activity Report (SAR) Proposal For Lenders and Brokers:

Financial Crimes Enforcement Network (Fin CEN) issued a notice of proposed rule(NPR) 12/6/10 to require ‘a loan or finance company’ to comply with Anti-money laundering programs and SAR reporting. (Yes, this would include lenders and brokers). The Secretary has authority to do so under the Bank Secrecy Act. They tried this in 2002 and it was pulled back to conduct studies on the impact...
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Appraiser Independence Rules Effective 4/1/11

October 28, 2010:  The FRB published the first rule for mortgage lenders under Dodd Frank to specify the requirements for the Appraiser Independence rules.  It is an ‘interim final rule’.  They accepted comments until December 27, 2010 but followed with a statement that mandatory compliance is April 1, 2011. Scope per Final Rule: Applies to creditors, appraisal management...
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Qualified Mortgage, Qualified Residential Mortgage And Risk Retention

Under Title XIV of the Dodd Frank Act federal regulators must establish minimum underwriting standards for residential mortgage loans by 4/15/11 (excluding reverse mortgages and bridge loans of up to one year). This referred to as the Qualified Mortgage standard (QM). The requirements will define how a lender will support the consumer has a reasonable ability to repay the obligation. The QM...
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2011 Bills We’re Watching

H 363: Forced Refinance Provisions For Fannie/Freddie Status: Introduced 1/20/11 The formal name of the bill is ‘Housing Opportunity and Mortgage Equity Act of 2011”. The bill would require Fannie/Freddie to create a     program for qualified mortgages where an appraisal is not required. The servicing fee will be restricted to a maximum of $1,000. H 330:  First Time Homebuyer...
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