(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,…
TILA RESPA Integrated Disclosure Enforcement; Pre-Close Audits Can help
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…
Are Wells Fargo’s Loans Too Safe to Fail?
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,…
Don’t Discriminate on Section 8
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…
The “HAWK” is DEAD! – Housing and Urban Development “Homeowners Armed with Knowledge”
As an alumni of Villanova University, the phrase “The HAWK is Dead! The “HAWK is Dead! I heard countless times during the annual basketball game between Villanova University (the Wildcats) and their Big Five rival St. Joseph’s University (the Hawks). This game typically proved to be a great match-up no matter what the rankings of the two teams and this…
Consumer Financial Protection Bureau & Department of Justice – Team Up on Redlining
Could redlining in mortgage lending still exist? According to CFPB and the Department of Justice, it sure does, and they are out to do something about it (Redlining). The CFPB and DOJ are putting out the word to all mortgage lenders that they believe redlining definitely still exists and that they are working closely together to identify and correct any…