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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The New World of QM

Posted by Krista Sabol on Mar 4, 2014 in Origination, QM/ATR Rule Managing The Change For Originators in the New World of QM Much has been written about the impact of the Qualified Mortgage (QM) and Ability to Repay (ATR) rules from a legal and compliance perspective. Have you noticed whether the stress of this buzz, throughout your company and the industry, is causing originator sales paralysis? In a recent training class of highly experienced originators, a...
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Did Your QM Implementation Feel Like Y2K or a Bomb?

Posted by Krista Sabol on Feb 4, 2014 in IMU Blog, QM/ATR Rule Change management Rules for Mortgage Lenders In one day I heard the QM regulation compared to Y2K and a nuclear bomb. Company A felt QM implementation was like Y2K because there was a lot of panic in the months leading up to January 10th and then nothing went horribly wrong the next day. This was clearly a testament to how well they prepared and found their process relatively unscathed by the...
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FHA Seller Concession Rules Proposal Issued

Posted by Krista Sabol on Mar 1, 2012 in FHA, IMU Blog, Origination, Processing, Proposed Rules, Rules Watch, Underwriting The long awaited details of the proposed rule to limit seller concessions is finally back in the federal register. A re-proposal requesting comments was published yesterday, Feb. 23 with a comment period open until March 26th. The new proposal combines a percentage cap with a dollar limitation and works like this (of course it isn’t just a straight forward policy!): The seller is permitted...
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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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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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FHA Fine Print Reduces Allowable Lender Contributions

Posted by Krista Sabol on Aug 6, 2010 in FHA, Processing, Proposed Rules, Underwriting FHA published a proposal on July 15th announcing changes to important underwriting requirements. Lenders and brokers must be aware of a problem in the fine print and respond to FHA immediately! FHA is not only changing the maximum seller contribution from 6% down to 3% they have changed the definition of ‘interested third party’ in a footnote at the bottom of page 41220. FHA’s 4155.1...
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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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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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