Posts on mortgage compliance and industry regulation including TRID, HMDA, and MERS.
A bi-partisan bill was introduced in Congress last week that intends to provide all lenders with a temporary reprieve from enforcement actions for violations under the new TILA-RESPA Integrated Disclosure (TRID) rules (Relief). Under the proposal, lenders would not be subject to enforcement actions through year end 2015. Eligibility would be based on the lender’s “good faith” efforts to comply…
The other day, I wrote about a bill pending in Congress that would make any loan, made by a Bank and held in portfolio, a bona fide QM (Unintended Consequences). It seems this has stirred some debate; not my blog but the issue of the Bank’s portfolio loan’s QM status (Controversy). At issue is whether a loan is of better…
A bill has been introduced in the House which would give existing Bank mortgage loan originators a temporary reprieve from licensing when moving from a bank to an Independent Mortgage Lender (LO Licensing). If passed this would make it much easier for originators to jump from a Bank, where they need not be licensed, to work for a Lender, where…
Here’s a little twist on the QM rules. Congress is considering a slight modification to the QM rules which would treat some loans held in portfolio by a Bank as a QM loan (New QM). My understanding of the law is that any loan held in portfolio by a Bank, like any other loan, would be considered a QM when…
In an official notice to all FHA-Approved Mortgagees, FHA announced on April 30, 2015 that it has extended the effective date for the policies contained within its new Single Family Policy 4000.1 Handbook from June 15, 2015 until September 14, 2015. These new underwriting, appraisal and Quality Control policies have been the focus of several of my previous Blogs and…
You are an underwriter processing a FHA loan transaction and the appraiser has reported that the subject property has a private well & septic system yet public utilities may be available. Should you require evidence of hook-up to the public system as a condition of your approval? HUD’s draft 4000.1 Handbook (which is scheduled to go into effect for loan…
