I was chatting with a friend, John Castiello, who works at Radian about the potential pitfalls associated with high Loan-To-Value lending. If you’ve followed my blog, you know my concerns. John mentioned that Radian, as well as most mortgage insurance companies, offers programs to insure lenders against loss in the event of the non-performance of these loans. That’s good for…
On May 18, 2015 the Housing and Urban Development/Federal Housing Agencies announced that a draft version of their Origination Thru Post-Closing/Endorsement Handbook is available on-line via a link from their HUDCLIPS web page. The link will direct them to the Handbook on the AllRegs online electronic policy platform. This is truly a step in the right direction for FHA as…
(Except from MarketLogics 5-18-15) Imagine that data quality and appropriate manufacturing of mortgage loans really do matter. Think about this quote from the NYTimes Opinion piece, Breaking Laws in the Mortgage Bubble. “The trial against Nomura and R.B.S. rebuts the widespread notion that banks’ greed during the bubble did not amount to lawbreaking, that somehow it was the housing crash,…
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…
Senate Banking Chair, Richard Shelby, introduced regulatory relief legislation known as the “Financial Regulatory Improvement Act of 2015”. Among other things, this Act calls for a safe harbor protection from a consumer Ability To Repay (ATR) claim for any loans held in portfolio by a bank, with a few restrictions. Some key provisions of the bill may be found here,…
The Consumer Financial Protection Bureau issued Bulletin 2015-02 (Section 8 HCV) advising lenders of the pitfalls of excluding a consumer’s income derived from assistance received under the “Section 8 Housing Choice Voucher Homeownership Program” (now there’s a mouthful). They also highlighted information on their website for consumers that it is illegal for lenders not to use this voucher income (CFPB…
