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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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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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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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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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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