The Consumer Financial Protection Bureau has released a new online tool to help creditors determine which properties are located in a rural or underserved area. The tool aids in determining the exemption for requiring escrow accounts for higher-priced mortgages. Regulation Z provides that if “During any of the three preceding calendar years, the creditor extended… Read More »
On October 13, 2015, the CFPB amended Regulation C expanding the reporting requirements. Included in the changes were the definitions of covered institutions and covered transactions, changes to public requests, submission of reports, along with new and modified data fields – for a total of 48 fields. The CFPB released its Compliance Guide that includes… Read More »
No Adjustment for Appraisals for Higher-Priced Mortgage Loans Exemption Threshold Section 129H of TILA establishes special appraisal requirements for “higher-risk mortgages,” termed “higher-priced mortgage loans” or “HPMLs” in the agencies’ regulations. The Agencies (the OCC, the Board, the Bureau, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA) and the Federal Housing… Read More »
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 »
The CFPB released the final rule amending and expanding reporting requirements under Regulation C and the Home Mortgage Disclosure Act. The 797 page rule includes the threshold for covered institution reporting, changes to covered transactions, requirements for large volume reporters, new reporting procedures, disclosure and privacy, along with new and modified data fields. Dates: Most… Read More »
The CFPB issued a bulletin providing guidance to the mortgage industry regarding marketing services agreements. The bulletin offers an overview of the federal prohibition on mortgage kickbacks and referral fees, and describes examples from the Bureau’s enforcement experience as well as the risks faced by lenders entering into these agreements. During the course of supervising… Read More »
The CFPB released an updated Readiness Guide that includes the October 3, 2015 effective date for the Know Before you Owe mortgage disclosure rule. The update offers guidance on how to evaluate readiness for complying with the mortgage rules changes. The guide includes a Readiness Questionnaire (beginning on page 10) to serve as a guide… Read More »
The CFPB issued a final rule, Amendments Relating to Small Creditors and Rural or Underserved Areas under the Truth in Lending Act (Rule). The Rule revises the Regulation Z definitions of “small creditor” and “rural area,” and makes technical changes and clarifications to other sections of Regulation Z and the related commentary. The revised definitions… Read More »
The NCUA adjusted civil money penalties for violations within its jurisdiction to account for inflation. Federal agencies must adjust civil money penalties at least once every four years to account for inflation. Dates: Effective: 09/23/2015 Recommended Actions: The adjustment should not impact the operations of the credit union, but the credit union should be aware… Read More »
The NMLS annual renewal period for MLOs is from November 1 to December 31. Both the credit union and mortgage loan originators must renew during this period. The NMLS provides this page with guidance on the renewal process and includes batch upload instructions for MLOs associated with the credit union. If the credit union has… Read More »
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