Posts on mortgage compliance and industry regulation including TRID, HMDA, and MERS.
In January of 2018, just about all mortgage lenders will be required to collect approximately 50 data elements identifying specific information about the consumers obtaining mortgages from them, and the terms and conditions under which they get them. This information is required by the CFPB under its power and guidance provided by the Dodd-Frank Act. This requirement will no doubt…
While Fannie Mae is talking about relieving lenders from some reps and warranties surrounding appraisals, Freddie is announced that it is doing away with the current traditional appraisal report. This is a bold move that leaves many up in arms. Not surprisingly, the biggest protesters are appraisers. Freddie says they may accept the use of automated valuation reports, supplemented by…
This is a question that I hear quite often when auditing loans. The argument is that “the guidelines” don’t require them. I say better be safe than sorry. The “guidelines” do say the lender is required to re-verify the income used to qualify the loan. How else can you re-verify self-employment income other than with tax transcripts? Letters from the…
The comment period for the changes to the CFPB “Know before You Owe” rule, better known to the industry as TRID, was up October 18th. The industry groups, i.e. MBA, ABA, CBA, etc. all submitted their comments. Did you? CFPB proposed several changes to the TRID rules based on issues raised by the industry and others. One key element they…
Besides the recent ruling in the PHH case, there are other things happening with the CFPB. First, some good news. Dodd-Frank requires the CFPB to review and assess the effects of any rules implemented under the Act. Accordingly, even though it’s only been 3 years since we got the QM rule, they are already hard at work evaluating its effect…
CFPB published notice that the new Fannie/Freddie Uniform Residential Loan Application is approved as a model form under ECOA (Publication). CFPB’s Official Approval: Regulation B § 1002.5(b) provides rules concerning requests for information about race, color, religion, national origin, or sex. Section 1002.5(c) provides rules concerning requests for information about a spouse or former spouse. Section 1002.5(d) provides rules concerning…
