Getting TRID QC Right

Posted by Krista Sabol on Jul 7, 2015 in Quality Control / Audit, Regulations, TRID To make implementation smoother, quality control teams should be involved in the planning process for TRID> Many companies have underestimated the resources needed and the cost to implement the new TILA-RESPA Integrated Disclosures (TRID) rules. Budgets have been thrown out the window, and management has implemented a “get it done, on time, at any cost” approach. As the implementation...
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New FHA Total Scorecard Guide Summary

Posted by Krista Sabol on Jan 9, 2012 in Appraisals, FHA, FHA/VA, IMU Blog, Operations, Origination, Processing, Quality Control / Audit, Underwriting What do I need to know about the new FHA Total Scorecard Guide? Download Copy Of The FHA Total Scorecard Guide 2011 As you may know FHA released a new FHA Total Scorecard Guide (TSG) with some pretty significant changes. Our team sat down and scrubbed the new TSG to identify and relay the changes to you on our blog. The details will most certainly be incorporated into our FHA Practical...
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Regulation Z High Priced Loan Definition Change Proposal

Posted by Krista Sabol on Feb 15, 2011 in Closing, Operations, Origination, Quality Control / Audit, TILA, Underwriting 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:

Posted by Krista Sabol on Feb 15, 2011 in Anti-Money Laundering, Quality Control / Audit, Rules Watch 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

Posted by Krista Sabol on Feb 15, 2011 in Appraisals, Origination, Processing, Quality Control / Audit 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

Posted by Krista Sabol on Feb 15, 2011 in Dodd Frank Act, Origination, Quality Control / Audit, Underwriting 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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Regulation Z ARM Changes – Still?

Posted by Krista Sabol on Jun 29, 2010 in Origination, Processing, Proposed Rules, Quality Control / Audit, TILA, Underwriting Regulation Z had a proposed rule with a comment period that expired 12/31/09. This proposal received over 3300 comments primarily focused on the section that would prohibit loan originator compensation based on the terms of the loan. Now that the financial regulatory reform bill has included the ‘prohibition on steering’ and restriction of loan originator compensation, we’ll be watching...
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FHA’S New Lender Approval World

Posted by Krista Sabol on Jun 29, 2010 in FHA, Origination, Quality Control / Audit, Underwriting FHA ML 10-20 outlined the provisions for HUD’s reform of the lender approval process. Effective May 20th 2011 most lenders must possess a net worth of at least $1m (20% must be liquid assets). The only exception is for small lenders as defined by the Small Business Administration: o mortgage & non mortgage brokers with $7million or less in gross receipts; o Banks, Savings institutions...
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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...
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