The ink is barely dry on the first loan application taken under the new TRID rules and mortgage lenders have something new (or old) to worry about. CFPB, in its continuing efforts to protect consumers against those unscrupulous lenders out there, has issued its “guidance” on Mortgage Services Agreements (MSAs). The guidance they issued basically says they don’t like these…
Author: Michael Vitali
The TRID Effect
Mortgage applications fell drastically last week and some believe it is the direct result of the new TRID rules (Apps Decline). Could it be that lenders were able to push many applications to the prior week due to the fears created by the need to comply with new disclosure rules? Do lenders have such powers to make buyers move up…
TRID: The Game Changer
Under TRID, lenders need to make sure they disclose their fees within 3 days of receipt of the loan application. For the lender’s fees and charges and those for which the borrower cannot shop there is a zero tolerance at the closing table. That means that the fees disclosed on the new Loan Estimate must be the same fee charged…
CFPB Offers Guidance On MSAs
Well, not really. The CFPB issued a long-awaited bulletin today (CFPB Bulletin 2015-05) labeled as their guidance on the use of Marketing Services Agreements (MSAs). The only real guidance that I could determine from reading the bulletin is not to be in an MSA arrangements. If you are, you do so at your own peril. The bulletin highlighted several enforcement…
The ABC’s of MSA’s
Now that TRID has arrived, with QM and ATR in the rear view mirror, the CFPB may start looking around for other areas of intended consumer protections. One which has recently come to light is MSA’s – Mortgage Services Agreements. Richard Cordray, CFPB’s Director, has made it pretty clear that he does not like these type arrangements as they may…
Happy Birthday TRID
Well, it’s finally here. Like it or not, TRID is born and for new loan applications taken, as of Saturday (10/3), lenders are required to follow the new rules. Mortgage lending may never be the same. Everybody sing and everybody dance… For the past 18 months, lenders have been primping and prepping to be ready for the roll out of…