Posts on mortgage compliance and industry regulation including TRID, HMDA, and MERS.
You remember TRID’s “Black Hole?” The circumstance created by the new rule whereby a lender is unable to reset fee tolerances once an initial Closing Disclosure is issued and fees increase but closing gets delayed for more than 3 days. The question remains, how can a lender recover a fee increase once a CD is issued but closing gets delayed…
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…
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…
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…
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…
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…
