Federal Mortgage Regulations
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The New Consumer Financial Protection Bureau
by Rachel Horman, Esq. Assistant Vice President & Senior Counselrachel@bankersadvisory.com The Consumer Financial Protection Act of 2010 (Title X of the Dodd-Frank Act) (“the Act”) established the Bureau of Consumer Financial Protection. On July 21, the rulemaking powers for most consumer financial protection laws will be consolidated and transferred from the following agencies to the […]
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New Uniform Appraisal Dataset (UAD) Rules
by Anna DeSimone, Presidentanna@bankersadvisory.com Effective for residential property appraisals with an effective data (date of inspection) on or after September 1, 2011, appraisal reports must be completed in compliance with the Uniform Appraisal Dataset (UAD). The rule applies to all conventional mortgage loans sold to Fannie Mae or Freddie Mac. The UAD is a component […]
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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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Borrower Repayment Ability is on the Radar
by Anna DeSimone, President The Federal Reserve Board has proposed a Rule to implement a provision of the Dodd-Frank Act that prohibits lenders from originating mortgages without regard to the borrower’s ability to repay the loan. Creditors must make a reasonable and good faith determination of that repayment ability, based on verified and documented evidence. […]
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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 […]