TRID may be delayed for a while. But, Lenders still need to be concentrating on compliance and quality. CFPB may be concentrating on more regulation, but, Fannie and Freddie continue their increased emphasis on defect management. FHA is now following suit with the announcement of their new defect taxonomy. The goal? Loans made with ZERO defects. You can bet on…
Pre-Closing (or Pre-Funding) Reviews Will Now Be Required on FHA Loans In HUD’s draft “Origination Through Post-Closing/Endorsement Handbook” it is stated that a mortgagee’s required Quality Control (QC) sample must comply with the following balance of pre and post-closing reviews: Pre-Closing Reviews – 10% or less of the QC sample size Post-Closing Reviews – 90% or more of the QC…
A Bill was been introduced in Congress, supported by a recent letter from the American Bankers Association (Letter), to allow a “hold harmless’’ period from enforcement actions after the new TILA RESPA Integrated Disclosure (TRID) rules take effect. Creditors, which have yet to satisfactorily test their system’s readiness to ensure compliance with the new rules, fear severe reprisals from the…
Okay, here’s a new one. Have you heard about this? Your Quality Control audits may work against you in a court of law (Hazardous QC). Wells Fargo may get slammed in court partly as a result of the findings from their internal quality control audit findings. Now, ain’t that a hole in the boat? With all the recent chatter about…
Under the new TRID rules, a lender is required to provide an applicant with the new Loan Estimate, along with other application disclosures, when the lender is in receipt of 6 items from the applicant; the name, address, income, estimate of value, SSN & loan amount. The lender may not require anything additional, including but not limited to, verification of…
Lenders – are you utilizing Service Providers (or Third Party Vendors) to assist you in your Operations? If so – are you properly monitoring the associated risks in employing such Firms? Read on! The Consumer Financial Protection Bureau (CFPB) fully expects supervised banks and non-banks to properly manage the associated risks with employing service providers (or third party vendors). These…
