Oregon – Semi-Annual Escrow Rate Adjustment

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 calculated by the most recent … Read More

Regulation C – HMDA Reporting Final Rule

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 provisions of the final rule … Read More

CFPB Provides Guidance About Marketing Services Agreements

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 mortgage lenders and enforcing federal … Read More

CFPB Readiness Guide for mortgage rule changes

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 in preparing for the mortgage … Read More

Amendments relating to small creditors and rural or underserved areas under the Truth in Lending Act

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 will affect the availability of … Read More

NCUA Civil Money Penalties Inflation Adjustment

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 of the increase penalties for … Read More

Regulation Z Annual Loan Threshold Adjustments

Dates: Effective January 1, 2016 Summary: The CFPB announced the 2016 thresholds for Regulation Z provisions governed by the CARD Act, the Home Ownership and Equity Protection Act and the Dodd-Frank Act. Recommended Actions: Credit unions should review the new limits and incorporate them into their policies and procedures. Detailed Analysis: CARD Act Annual Adjustments: The safe harbor penalty fees … Read More

NMLS Renewal

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 merged with another institution during … Read More

Complying with the Military Lending Act

The Military Lending Act (MLA), along with the Servicemember’s Civil Relief Act (SCRA), provides protections to our servicemembers.  Both of these Acts were developed to help ease the legal and financial burdens on servicemembers actively serving our country and allow them to focus on their duties. The MLA came as result of the Talent-Nelson Amendment to the John Warner Defense … Read More