According to The Community Home Lenders Association (CHLA), non-bank mortgage lenders seem to more regulated when it comes to consumer lending protections than their bank counterparts (Regulations). When is enough, a little too much? Since the crash of 2008, Congress has passed a whole bunch of new rules and regulations. Most of these are a result of the infamous Dodd-Frank…
A Loan Is as Good as Its App
For many years, I worked for a large, successful luxury home builder located in the Pennsylvania area, which will remain nameless. One thing we all know is that a home is only as good as its foundation. Poor foundation equals a poor quality home. That builder is very successful to this day because their homes are built on a solid…
One More Hurdle for Mortgage Lenders
As if the housing crash, more regulations, increased agency scrutiny and CFPB oversight didn’t create enough challenges for Independent Mortgage Bankers, along comes potential new Ginnie Mae increased cash and liquidity requirements (Ginnie Requirements). With Independent Mortgage Bankers taking a lead role as issuers of Ginnie securities, along comes a concern that such lenders may not have the financial capacity…
Impact of FHA Handbook Policy Changes
If you have been reading our LoanLogics Blogs and Newsletters as well as other industry publications, you are aware of the fact that the policies outlined in FHA’s 4000.1 Handbook (for the most part) became effective on September 14, 2015. This 800+ page Handbook will provide a single reference point for FHA underwriting, Quality Control & appraisal policies. More importantly,…
TRID Uncertainty Drives Need for Enforcement Delay
With the TRID rules effective date just around the corner, the industry is pushing Congress hard for legislation to impose an enforcement moratorium. Lenders are concerned that honest mistakes/errors may take place as the result of the complexity of the new rules, the massive programming changes required for compliance, the exactness of the new forms and remaining uncertainty over implementation…
New FHA Certs May Deny Loans to Some
FHA requires lenders to sign an annual and individual loan certification that basically states the lender originates loans for FHA insurance in compliance with all related FHA rules and requirements. If the lender is found to have violated these rules, the lender may be fined and prohibited from further participation in the FHA lending program. In some cases, the lender…