Independent Mortgage Lenders are becoming major players as issuers of Ginnie Mae securities. Major banks like Wells Fargo, Chase and Bank of America have pulled back on FHA lending because of the increased risk plus past and potential enforcement actions from Federal Housing Administration (FHA) and Department of Justice (DOJ). This opens the door for non-bank lenders to fill the…
I was chatting with a friend, John Castiello, who works at Radian about the potential pitfalls associated with high Loan-To-Value lending. If you’ve followed my blog, you know my concerns. John mentioned that Radian, as well as most mortgage insurance companies, offers programs to insure lenders against loss in the event of the non-performance of these loans. That’s good for…
A Bill was been introduced in Congress, supported by a recent letter from the American Bankers Association (Letter), to allow a “hold harmless’’ period from enforcement actions after the new TILA RESPA Integrated Disclosure (TRID) rules take effect. Creditors, which have yet to satisfactorily test their system’s readiness to ensure compliance with the new rules, fear severe reprisals from the…
Senate Banking Chair, Richard Shelby, introduced regulatory relief legislation known as the “Financial Regulatory Improvement Act of 2015”. Among other things, this Act calls for a safe harbor protection from a consumer Ability To Repay (ATR) claim for any loans held in portfolio by a bank, with a few restrictions. Some key provisions of the bill may be found here,…
The Consumer Financial Protection Bureau issued Bulletin 2015-02 (Section 8 HCV) advising lenders of the pitfalls of excluding a consumer’s income derived from assistance received under the “Section 8 Housing Choice Voucher Homeownership Program” (now there’s a mouthful). They also highlighted information on their website for consumers that it is illegal for lenders not to use this voucher income (CFPB…
Could redlining in mortgage lending still exist? According to CFPB and the Department of Justice, it sure does, and they are out to do something about it (Redlining). The CFPB and DOJ are putting out the word to all mortgage lenders that they believe redlining definitely still exists and that they are working closely together to identify and correct any…
