Mortgage Compliance

Last Ditch Effort to Delay HMDA

Better late than never, I guess. The Community Home Lenders Association sent a letter to acting CFPB Director Mulvaney seeking a delay in implementation of the new HMDA data collection and reporting requirements. That’s like betting on a long shot. They believe the new requirements are an unfair burden on small independent lenders. Further, they want a safe harbor from…

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do-what-you-say-you-mean-fixx-tila
Mortgage Compliance

Do What You Say and Say What You Mean

TILA requires a lender to provide an applicant with a good faith estimate of the fees that will be charged to, or imposed on, the applicant in connection with their loan. Seems simple, if you’re gonna charge it; disclose it. There’s a little catch, the fee must be for a service that is actually provided by the lender. For example:…

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