ORS 86.245 requires that Oregon State lenders who require security protection in connection with a real estate loan to pay interest on funds in an escrow account of at least the discount rate. The rate is adjusted semiannually, and calculated on May 15 and November 15, and covers the following six-month period. The discount rate is… Read More »
UPDATED On March 31, President Obama signed into law the “Foreclosure Relief and Extension of Servicemembers Act of 2015,” extending the sunset date to December 31, 2017. Credit union’s SCRA Notices should (again) reflect one-year, rather than 90 days. The Service Members Civil Relief Act provides protection for service members from foreclosure for a… Read More »
In response to the Helping Expand Lending Practices in Rural Communities (HELP) Act, the CFPB issued an Interim Final Rule, which expands eligibility for the special provisions allowing balloon-payment qualified mortgages and balloon-payment high-cost mortgages and for the escrow exemption. Pursuant to the Interim Final Rule, a small creditor is no longer required to extend… Read More »
The CFPB has posted HMDA file specifications for 2017 and 2018. For data collected in 2016, credit unions should follow the FFIEC’s file specifications. For data collected in 2017 and data collected in or after 2018, credit unions should follow the CFPB’s file specifications. _ _ _ As a reminder, The NCUA released a Regulatory… Read More »
Washington and Oregon’s legislature is back in session after the holidays, and both states have a couple bills that, if enacted, would have impact on credit unions. In Washington, Senate Bill 5635 would repeal Washington’s Power of Attorney Act and replace it with a modified Uniform Power of Attorney Act – which 18 states have… Read More »
NCUA Letter 16-RA-01 The NCUA released a Regulatory Alert reminding credit unions of the requirement to collect and report HMDA data during 2016. The credit union must collect HMDA data during 2016 if: Your credit union’s total assets as of December 31, 2015, exceed $44 million; Your credit union had a home or branch office… Read More »
In December, the CFPB responded to a letter from the Mortgage Bankers Association regarding “lingering misperceptions and technical ambiguities” in TRID regulations. The CFPB’s letter states that, given inevitable yet unintentional errors in the early stages of the mortgage industry’s implementation of the regulations, regulators’ initial examinations will focus on industry members’ good faith efforts to ensure compliance… Read More »
Version 2016 for CY 2016 data due March 1, 2017 is now available from the FFIEC. Each software version is year-specific (i.e., 2015 reporting requires 2015 DES and not 2016 DES). System Requirements The software must be installed locally on a hard disk; it is NOT network compatible. Minimum OS: Microsoft Windows Vista or Windows… Read More »
Homeowners that the credit union has provided a Notice of Default to, and lived in their home when the foreclosure processes started, are eligible to participate in Washington State’s Foreclosure Fairness Act Mediation Program, unless the credit union has conducted less than 250 foreclosure sales during the previous year, and claimed their exemption status to… Read More »
The CFPB has announced two final rules with annual threshold adjustments under the implementing regulations for the Home Mortgage Disclosure Act (HMDA) and the Truth in Lending Act (TILA). The HMDA asset-size exemption threshold under Regulation C is unchanged at $44 million. Institutions with assets of $44 million or less as of December 31, 2015,… Read More »
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