Mortgage Compliance

Federal Gov’t: Can we please have more time!

Time is Running Out
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Time is Running OutWell, it is finally April and thoughts of many Americans are to seek an extension from the Federal Government regarding the filing of their Tax Returns.  However, the topic of this Blog Post is not income taxes but two widely discussed mortgage industry initiatives that have effective dates looming and extensions being sought by many entities.

In Mike Vitali’s, B-Logics’ Blog Post, Hop To It!, dated March 31, 2015, the possibility of the CFPB extending the start date beyond August 1, 2015 for the new TILA RESPA Integrated Disclosure (TRID) rules was discussed in great detail.  Mike’s message was for industry groups to start preparing for these new rules since the CFPB has been making it clear that they currently have no intentions of extending the August 1st deadline.

Now, the word from the Mortgage Bankers Association (MBA) is that they have formally requested an extension from HUD/FHA of its planned implementation of its Single-Family Housing Policy Handbook (4000.1) from June 15, 2015 to at least December 1, 2015.

The MBA has requested this delay because, with less than three months from the June 15th start date, there are numerous policy changes being implemented that need additional clarification and some that tend to conflict with one another.

One other concern is that lenders will need more time to adjust their loan origination systems with HUD’s and that a TOTAL Developers Guide with all appropriate changes should be finalized in advance of the effective date.

Although HUD/FHA is conducting some webinars to discuss the proposed changes [the next one is scheduled for April 8, 2015 at 2pm EDT], these webinars hardly scratch the surface in evaluating all of the substantive changes being contemplated and few, if any, questions are solicited from participants.

The FHA policies and procedures that are being impacted by the implementation of this new Handbook have been and will continue to be, the focus of many of my Blog Posts.

It is my hope and expectation that many of our industry partners will share the concern that an extension to the June 15, 2015 effective date is certainly needed if lenders are to be held accountable for compliance with the numerous new requirements.

Stay tuned!

Gerry Glavey

About the Author

Gerry Glavey

Gerard (Gerry) Glavey is Senior Vice President / Chief Credit Officer for LoanLogics. Gerry has decades of experience working in residential mortgage credit and compliance and brings insights that few in the industry can match. In his role, he develops new services and provides support for all post close quality control and quality assurance, pre-close quality control, due diligence services, and document processing services. He spent 37 years with the US Department of Housing and Urban Development, where most recently he was the Director, Processing and Underwriting Division for the Home Ownership Center (HOC) in Philadelphia. In this capacity, Mr. Glavey was responsible for the administration of all HUD/FHA Single Family Loan Origination activities, including underwriting, appraisal and endorsement for the 16 state jurisdiction of this HOC.
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Gerry Glavey

About Gerry Glavey

Gerard (Gerry) Glavey is Senior Vice President / Chief Credit Officer for LoanLogics. Gerry has decades of experience working in residential mortgage credit and compliance and brings insights that few in the industry can match. In his role, he develops new services and provides support for all post close quality control and quality assurance, pre-close quality control, due diligence services, and document processing services. He spent 37 years with the US Department of Housing and Urban Development, where most recently he was the Director, Processing and Underwriting Division for the Home Ownership Center (HOC) in Philadelphia. In this capacity, Mr. Glavey was responsible for the administration of all HUD/FHA Single Family Loan Origination activities, including underwriting, appraisal and endorsement for the 16 state jurisdiction of this HOC.
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