Alice Reviews HMDA Changes on Blog Talk Radio

Posted by Krista Sabol on Mar 1, 2016 in HMDA, Weekly Legislative Update As most of you are aware, the Consumer Financial Protection Bureau (CFPB) finalized the Home Mortgage Disclosure Act (HMDA) rule in October 2015. With all the focus on TRID, many are not aware that the new HMDA rule adds 25 new data points and modifies 14 others in addition to the existing 9 data fields that were already required. Additionally, lenders now must begin to start reporting data on...
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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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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...
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TRID TIP OF The Week

Posted by Krista Sabol on Feb 17, 2015 in Regulations, RESPA, TILA, TRID Explaining Total Interest Percentage (TIP) Originators and closers will be faced with a new acronym on the Loan Estimate(LE) and Closing Disclosure (CD). They will need to explain the Total Interest Percentage or TIP to the borrower. The TIP is the total amount of interest the borrower will pay over the loan term as a percentage of the loan amount. The TIP is shown along with the APR, Finance...
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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...
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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...
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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...
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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...
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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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2011 Bills We’re Watching

Posted by Krista Sabol on Feb 15, 2011 in Dodd Frank Act, Legislative Watch, Regulations, VA 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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Clarification – Risk Base Pricing Disclosures Made Easy (?)

Posted by Krista Sabol on Jan 7, 2011 in Fair Credit Reporting Act, Final Rules One of my new year’s resolutions is to be very diligent in creating a valuable newsletter every week. My second resolution is to make sure I have it proofed three times before sending. The newsletter article titled “Risk Based Pricing Disclosures Made Easy”sent out on December 30th, 2010 describes the lender’s option to issue a Residential Mortgage Credit Score...
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Risk Based Pricing Disclosures Made Easy (?)

Posted by Krista Sabol on Jan 3, 2011 in Fair Credit Reporting Act, Final Rules Like RESPA in 2010 we are faced with a yearend disclosure that at first can seem relatively straight forward but the details start to make operations managers nervous. The Risk Based Pricing (RBP) policies and disclosures required as of 1/1/11 will need some attention to make sure both the technology and operations have been considered. The regulation requires creditors (therefore not mortgage...
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Land Contracts

Posted by Krista Sabol on Jul 1, 2010 in Origination, SAFE Act Realtors and builders are realizing that their new state licensing laws may include a provision to require a license when you sell a non-owner occupied property on a land contract. Many people have never used or heard of land contracts. They were popular in the late 70’s, early 80’s and prior when mortgage’s didn’t have a due on sale clause. Under a land contract, the seller retains...
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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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Texas Mortgage Bankers Association MDIA Summary

Posted by Krista Sabol on Mar 5, 2010 in IMU Blog, MDIA, TILA Texas Mortgage Bankers Association MDIA Summary July 2009 The Texas Mortgage Bankers Association has published one of the clearest write ups that I have seen related to MDIA. For those of you still trying to confirm that your policies are correct, I recommend this bit of light reading. It’s only 6 pages and gets straight to the point. It’s also a great tool if you are new to compliance and...
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FDIC Examination Procedures TILA and MDIA

Posted by Krista Sabol on Mar 5, 2010 in IMU Blog, MDIA, TILA The best way to know how to prepare for an audit is to know the procedures the regulator will use when they come on site.  The attached FDIC procedures have some helpful tools even if you are regulated by another entity. Here are my cliff notes: 1)      there is a helpful finance chart on page 11 2)      Page 29 -32 have great flow charts to illustrate when the finance charges...
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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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Texas MBA MDIA Summary

Posted by Krista Sabol on Feb 23, 2010 in IMU Blog, MDIA, TILA The Texas Mortgage Bankers Association has published one of the clearest write ups that I have seen related to MDIA. For those of you still trying to confirm that your policies are correct, I recommend this bit of light reading. It’s only 6 pages and gets straight to the point. It’s also a great tool if you are new to compliance and need to get a handle on MDIA in a hurry.
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