Now that TRID has arrived, with QM and ATR in the rear view mirror, the CFPB may start looking around for other areas of intended consumer protections. One which has recently come to light is MSA’s – Mortgage Services Agreements. Richard Cordray, CFPB’s Director, has made it pretty clear that he does not like these type arrangements as they may…
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…
With the passage of the Affordable Health Care Act (an oxymoron), the health care industry has come even closer to being run by the federal government. Is Banking headed down that same path? (Dodd-Frank Costs). You’re probably wondering where I’m going with this one. Under the Affordable Care Act, everyone is forced to carry health insurance coverage. The coverage required…
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,…
Your options are limited! Lenders beware – the financing of Bed & Breakfast facilities can result in a Repurchase or Indemnification Agreement Request. Recently, a client asked our Firm about financing opportunities for a Bed and Breakfast establishment. Usually located in resort areas, Bed & Breakfasts are private homes offering overnight accommodations that include private bedrooms and either a private…
If you want to capture the Millennial homebuyers, you may need to provide some upfront education. Studies have found that many of this generation, although being tech savvy, know little about the home buying and financing process (Millennial Knowledge). Millennials are now moving into the home buying stage and will be shopping for their homes and related financing. Most will…
