The CFPB recently issued what it calls their new ‘no-action letter’ to Upstart Network, a San Carlos, CA company that makes personal loans to consumers. The reason; Upstart will use and evaluate certain alternative credit and other consumer data when making credit decisions on their applicants. The CFPB’s apparent intent, through these no-action letters, is to encourage lenders to develop…
Category: Mortgage Compliance
Posts on mortgage compliance and industry regulation including TRID, HMDA, and MERS.
What’s Next? TRID 3.0 or Maybe TRIDIA
With the TRID 2.0 changes finalized and changes to address the ‘Black Hole’ out for comment, some in Congress are already looking at additional upgrades to the Rule. A Bill sponsored by Representative French Hill (R /AK) was introduced for discussion in the Financial Institutions and Consumer Credit Subcommittee of the House Financial Services Committee. Try and say that one…
Make Sure You Provide the Correct Shopping List
The updates to the TRID rules, recently released by CFPB, include a clarification of the tolerance limits for the fees for the services for which a consumer may shop when a service provider list is not provided. These are the fees disclosed to a borrower in Section C of the Loan Estimate. TRID requires a lender to disclose all fees…
Appraisers Beware! Freddie Goes One Step Further
Freddie announced that they have received approval to move forward with their plans to waive a lender’s requirement to obtain and submit a full residential appraisal report on a purchase loan transaction. This is one step further than Freddie and Fannie had gone when they waived appraisals on certain refinance loans. Freddie says that they will provide these waivers on…
Could GSE Reform Be More Than We Bargained For?
There are all sorts of ideas floating around about ultimate GSE reform. Everyone believes their plan is the best. What would be best for the GSE’s and the industry? Should we have one combined agency with some sort of government backing? Should both Fannie and Freddie stay as is but go private? Should they operate like Ginnie? Now, we hear…
Don’t Do The Crime and You Won’t Pay the Fine
Since 2008, the Department of Justice (DOJ) has drastically increased its use of the False Claims Act (FCA) to go after what say are bad actors in FHA mortgage lending. Since 2009, they have collected fines and penalties totaling more than $7 billion. That ain’t chump change. Many banks discontinued making FHA loans and some nonbank lenders became increasingly more…