More about Marissa Blundell
Blog Posts by Marissa Blundell:
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CFPB Rule for Alternative Mortgage Transaction Parity Act
by Marissa Aquila Blundell, Esq. Senior Counsel & Vice Presidentmarissa@bankersadvisory.com On July 22, 2011, the Consumer Financial Protection Bureau (CFPB) issued an interim final rule which preserved the ability of state housing creditors to make alternative mortgage transactions notwithstanding state law prohibitions. However, the rule incorporates amendments to the Alternative Mortgage Transaction Parity Act (AMTPA), required […]
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Fair Credit Reporting Act Risk-Based Pricing Regulations Update
by Marissa Aquila Blundell, Esq. Senior Counsel & Vice Presidentmarissa@bankersadvisory.com On July 6, 2011, the Federal Reserve Board (FRB) and Federal Trade Commission (FTC) published a final rule adding requirements to the Fair Credit Reporting Act (FCRA) Risk-Based Pricing regulations which were effective January 1, 2011. This article highlights the new requirements implemented in accordance with […]
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Dodd Frank Issues Rule on Adverse Action Notices
by Marissa Aquila Blundell, Esq. Senior Counsel & Vice Presidentmarissa@bankersadvisory.com The Federal Reserve Board (FRB) and Federal Trade Commission (FTC) issued a final rule on July 6, 2011 requiring creditors to provide additional information in adverse action notices if a credit score is used in making the credit decision. The new rule is effective 30 days […]
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Dodd Frank QM – Proposed Alternative Definitions
by Marissa Aquila BlundellSenior Counsel & Vice Presidentmarissa@bankersadvisory.com The Dodd Frank Act prohibits a creditor from making a residential mortgage loan unless the creditor makes a reasonable and good faith, verified determination that the consumer has a reasonable ability to repay the loan. This determination of a consumer’s ability to repay must be […]
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Dodd Frank QRM – Proposed Rules for Credit Risk Retention
by Marissa Aquila BlundellSenior Counsel & Vice President Amid the frenzy surrounding implementation of new Loan Officer Compensation rules, on March 29, 2011 the mortgage industry received the first of two major regulatory proposals issued in accordance with the Dodd Frank Wall Street Reform and Consumer Protection Act (Dodd Frank). The proposed rule is a […]
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LO Comp Rules Now in Effect – Fed and HUD Provide Clarification
by Marissa Aquila BlundellSenior Counsel & Vice President The Federal Reserve Board’s new rules governing originator compensation are now in effect. After a five day court-imposed administrative delay, the United States Court of Appeals denied a request to further delay implementation of the rule. In March, the industry received additional guidance related to the new […]
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Federal Reserve Clarifies Loan Officer Compensation Rules
Dear Reader, March has been an exciting month for Bankers Advisory. We have exhibited at the New Jersey Regional Mortgage Bankers Conference and are now heading to the Mortgage Bankers Association Annual Fraud Conference in Fort Lauderdale. We’ll be exhibiting again at the American Bankers Association’s Real Estate Lending Conference April 10-12th in Baltimore. […]
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Truth-in-Lending Change Applies to Jumbo Mortgages
by Marissa Aquila Blundell, Esq.Vice President & Senior Counsel The Federal Reserve Board recently amended TILA to provide a separate, higher rate threshold for determining whether a “jumbo” loan is subject to the same escrow requirements as non-jumbo Higher Priced Mortgage Loans (HPMLs). Effective April 1, 2011, if a jumbo loan’s APR exceeds the average […]
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Federal Registry for National Licensing Now in Effect
by Lindsay Sayre Kift, Esq.Associate Counsel and Client Services Director The Race Is On: NMLS Federal Registry Opens On Monday, January 31, 2011, the Conference of State Bank Supervisors (“CSBS”) announced the opening of the Nationwide Mortgage Licensing System (“NMLS”) Federal Registry. NMLS is now accepting registration filings from institutions and mortgage loan originator (“MLO”) […]
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Key Points to Truth-in-Lending Changes Effective January 30th
by Marissa Aquila Blundell, Esq.Vice President and Senior Counsel Next week, all creditors who are responsible for issuing Truth-in-Lending disclosures must comply with new rules. The Federal Reserve issued these rules to implement additional provisions of the Mortgage Disclosure Improvement Act (MDIA). For applications received on or after January 30, 2011, lenders must disclose how […]