The Road To HMDA Implementation

Posted by Krista Sabol on Jan 16, 2017 in Compliance, IMU Blog HMDA is not the same as TRID; lots of testing and training will be needed. Reprinted with permission from the October 2016 issue By Alice Alvey The need to collect accurate data for the Home Mortgage Disclosure Act (HMDA) is buried deep beneath the pressure to close loans on time. It’s a common afterthought and also a misconception that data can be fixed later if it isn’t right the first...
read more

Fair Lending – One Loan and One Gap Is All It Takes

Posted by Krista Sabol on May 23, 2015 in Compliance, Fair Lending, IMU Blog Complying with fair lending laws has quantitative and qualitative aspects both of which must be covered in thorough and well-written procedures. One case study of an FDIC (Federal Deposit Insurance Corporation) audit demonstrates just how critical developing and upgrading procedures for both elements are to a company. It only takes one loan for a problem For the year being reviewed, the...
read more

Integrated Disclosure ‘Business Purpose’ Nightmare

Posted by Krista Sabol on Feb 8, 2015 in Compliance, Regulations, RESPA, TILA To disclose or not to disclose, that is the question for non-owner occupied residential loans under the integrated disclosure rule. TILA and RESPA have long stated that disclosures under their rules do not apply to a business purpose loan. Technically a loan used to purchase or refinance a rental property today does not need a GFE or TIL. But as an industry, we like standard procedures that are...
read more

Negative Approach On TRID Causes Problems

Posted by Krista Sabol on Feb 4, 2015 in Compliance, IMU Blog, Regulations, TRID Most companies have not had the time to identify the positive impact of the Truth In lending, RESPA Integrated Disclosures (TRID) that must be used with applications beginning 8/1/2015. It seems integrated disclosure education events are focused on raising everyone’s level of panic. I admit there is cause for panic if you are just starting to identify procedural changes but be careful about...
read more

TRID in the Weeds

Posted by Krista Sabol on Jan 23, 2015 in Compliance, IMU Blog, News, Regulations, RESPA, Rules Watch, TILA by Alice Alvey for Mortgage Compliance Magazine As we step into 2015, mortgage lenders, brokers, depositories, and vendors are at various stages of understanding and preparing for the TILA-RESPA Integrated Disclosure (TRID) rule (Rule). In an informal survey of various audiences over the last few weeks, it seems that roughly 60% are beyond the initial discovery phase and are actively...
read more

Completing Your Compliance Management System

Posted by Krista Sabol on Jun 6, 2014 in Compliance, IMU Blog, Regulations Simply having written policies and procedures is not a compliance management system. The key word here is “management”. Compliance management means tracking specific details within every regulation and validating implementation. Indecomm-Mortgage U’s Health Check is your compliance management tool. The key benefit to the Health Check service is the IMU team of compliance...
read more

The Red Flags Rule: Deadline Extended

Posted by Krista Sabol on Mar 1, 2010 in Compliance, Final Rules, IMU Blog, Quality Control / Audit, Red Flags Rule The Red Flags Rule has been extended three times. Lenders are required to have a written policy in place no later than December 31,2010. Don’t expect an extension again! (Well maybe) Attached is a sample red flags policy that is available at the FTC website. For those of you at a small to midsized community bank or credit union, lender or broker, you may find that this template is the best...
read more