04
NOV
2014
Michael Vitali, Chief Compliance Officer at LoanLogics

The incredible shrinking buyers

Much is being written about the decline in young, first time homebuyers (Washington Post Article). Why are fewer young people deciding to buy? Well, how about the burden they carry from their student loans which had the rates increased and can only be obtained through government...
03
NOV
2014
Michael Vitali, Chief Compliance Officer at LoanLogics

More than just some new forms…

With the upcoming changes to TILA & RESPA requiring two new disclosures; the Loan Estimate and the Closing Disclosure comes new potential for stricter penalties for failures to comply (NMN 11-3 Story). With the combination of the requirements for the new disclosures under...
30
OCT
2014
Michael Vitali, Chief Compliance Officer at LoanLogics

Regulatory Reality

Where have these guys been for the past year, living in a dream world of non-reality? (NMN Article) I commented on this very issue almost a year ago (Newsletter). Rather than complaining about regulation and requirements, embrace them and learn to use
29
OCT
2014
Michael Vitali, Chief Compliance Officer at LoanLogics

FHFA Changes to Loosen Credit

Now here’s a guy who is thinking straight (The Story).  Richard Davis, CEO at US Bancorp is taking a “wait and see” approach to doing loans under proposed relaxed credit standards announced by FHFA (Fannie & Freddie). Not a bad idea in view of past experiences lenders...
23
OCT
2014
Michael Vitali, Chief Compliance Officer at LoanLogics

Under the new combined disclosure rules for TILA & RESPA, who will issue your Closing Disclosure?

Looks as though Wells Fargo, one of the nation’s biggest lenders, has decided they will do this in house (Read Here). Hopefully, you are aware that for loans originated as of August 1, 2015 (nine months from now) you will be required to provide the consumer with a new...
23
OCT
2014
Michael Vitali, Chief Compliance Officer at LoanLogics

Some Good News from CFPB…

CFPB announced some minor changes to the ATR and QM rule (CFPB). Read all about it. The allowable refund of fees which exceed the QM thresholds is a good one. Under the changes, a lender has the opportunity to refund such an overpayment within 210 days after the closing. So, if...
21
OCT
2014
Michael Vitali, Chief Compliance Officer at LoanLogics

Half Full or Half Empty?

FHFA talks of relaxing reps and warranties to help lenders get a better comfort level on potential for repurchases and indemnifications (Read MBA Newslink story). In the words of Mel Watt, new director of FHFA, the hope is that these changes will facilitate market liquidity...
20
OCT
2014
Michael Vitali, Chief Compliance Officer at LoanLogics

Compliance Costs on the Rise… Surprised?

A recent article in Origination News cited that mortgage lending compliance costs are up almost 30% year over year (Origination News). That should not come as a surprise to anyone in view of the new requirements for QM loans and ATR under Dodd-Frank, coupled with increased...
15
OCT
2014
Michael Vitali, Chief Compliance Officer at LoanLogics

CFPB Proposes Changes to New Integrated Rule

On Oct 14, 2014, the CFPB announced some changes to the new TILA – RESPA integrated rule introducing the new Loan Estimate and Closing Disclosure.  These will replace the current GFE, TIL and HUD-1. If you are not already familiar with the new integrated rule, and these new...
10
OCT
2014
Michael Vitali, Chief Compliance Officer at LoanLogics

Wells pays big bucks to settle maternity case

Looks as though lenders are getting caught in the ability to repay squeeze (Wells Article).  TILA requires a lender to ensure the consumer has the ability to repay the new mortgage debt. To do so, a lender, among other things, must determine that the consumer makes sufficient...