Posts on mortgage compliance and industry regulation including TRID, HMDA, and MERS.
Back in July, MERS sent a reminder notification to its customers about their upcoming 2019 eQA Plan responsibilities. During that same time, I penned a blog to help servicers begin those preparations in a timely and well-executed manner with their 3rd party provider. Part of that guidance recommended starting the process three to four months out from the time of…
As a part of the overall standardization efforts of the government sponsored enterprise (GSEs) Fannie Mae and Freddie Mac as directed by their regulator, the Federal Housing Finance Agency (FHFA)’s Uniform Mortgage Data Program (UMDP) is the latest “U” initiative coming to market is aimed at the loan application. Everyone from the borrower, to the loan originator, quality control vendors…
Today we are going to discuss the confusion surrounding the application of real estate tax credits to the borrower’s closing costs and (MRI) minimum required investment, when applicable. If you are just as confused, this blog is for you. In some state’s property taxes are paid in the arrears which means that the borrower is paying for “services” the municipality…
Often, underwriters are faced with a borrower, especially a self-employed borrower, whose income has declined year over year. I wanted to provide a quick review regarding declining income for self-employed borrower(s) specifically for FHA loans. There are a few paths a loan can follow. When income is declining year over year, it affects how the borrower’s income is calculated as…
Last July, Fannie Mae began accepting loans with debt to income (DTI) ratios up to 50%. This is much higher than that allowable under the Truth Lending Act (TILA) for a Qualified Mortgage (QM). However, TILA offers an exception to the QM rules for loans that get approved by Fannie’s Automated Underwriting System (AUS). For now, as long as the…
Will the Consumer Financial Protection Bureau (CFPB) become a mere shell of its former self? Appears so, if Mick Mulvaney, its current Acting Director, has his way. Since its creation, the financial institutions that it regulates have decried that the CFPB is overbearing in pursuing its mission to protect consumers. CFPB’s approach has been to regulate by enforcement of laws…
