Posts on mortgage compliance and industry regulation including TRID, HMDA, and MERS.
Beginning in 2019, lenders must report an additional 24 loan data elements under HMDA, collected for loans originated in 2018. This means lenders must be prepared by January 1, 2018, to capture these data elements. A complete list of the required data can be found at HMDA. Lenders have expressed concerns with the additional consumer information being captured. Does this…
With everything going on surrounding Brexit: low rates, increased refinances and the presidential race you may have missed a deadline. Effective for all FHA case numbers issued/assigned as of June 27, 2016, FHA-approved lenders must deliver appraisal reports through FHA’s new EAD (Electronic Appraisal Delivery) portal. If you missed the deadline, you’re probably okay as you most likely do not…
Wholesale lenders and brokers are looking to CFPB to clarify TRID rules for disclosures. Many hope this clarity will come with the new proposed rulemaking in July. For now, concern and confusion exist. (Disclosure) Under the new rules, CFPB has made it quite clear that the lender making the loan is the entity responsible for compliance. The lender may delegate…
In case you missed it, on June 8th FHA announced that their TOTAL (Technology Open To Approved Lenders) automated underwriting system will no longer provide the upfront or annual mortgage insurance premium factors required for a loan (FHA Info #16-36). These factors may be found in Appendix I to the new FHA Single Family Housing Policy Handbook 4000.1 (Handbook). This…
Last week, during a webinar LoanLogics presented as an ABA-endorsed provider, a question was raised about the calculation of the basis for the 10% fee tolerance under TRID. In my response, I mentioned that I had covered this topic in a recent blog. I stand corrected. After checking, I realized this was inaccurate. I had covered this topic in my…
Under the TRID rules, a lender may increase a fee once disclosed as being non-shoppable by the consumer when the result of an event or circumstance taking place after a disclosure is issued. These are known under the law as “allowable changes in circumstances.” In such justifiable situations, a fee which is directly related to the change may be increased.…
