With the TRID changes looming large, Brokers are taking their concerns about fee disclosures to Congress. It seems Brokers have realized that, the fees they disclose at application must be accepted by any Lender with which they decide to subsequently register a loan. The Brokers believe the new rules governing the Loan Estimate will make it more difficult for them…
Category: Mortgage Compliance
Posts on mortgage compliance and industry regulation including TRID, HMDA, and MERS.
TILA-RESPA Integrated Disclosure – How Do You Spell Relief?
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 Great QM Debate
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…
Big League for LOs
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…
The Rules of Unintended Consequences
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…
Extension Granted for FHA’s New Underwriting Policies
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…