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CFPB and Fed Increase Reg Z Dollar Threshold
by: Marissa Aquila Blundell, Esq. On November 20, 2012, the Consumer Financial Protection Bureau (CFPB), jointly with the Federal Reserve Board (FRB) where applicable, issued three final rules which adjust certain monetary thresholds in the Truth-in-Lending Act’s (TILA) Regulation Z and Consumer Leasing Act’s (CLA) Regulation M. The Dodd-Frank Wall Street Reform and Consumer […]
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Vermont Issues Clarification for High Rate Loan Qualification
by: Emily Ross, Esq. The Vermont Department of Financial Regulation recently released a memorandum clarifying interest rates set for High Rate Loans for the 2013 calendar year. Vermont law states that any lender granting loans that charge borrowers in excess of four points or interest in excess of three percent over the declared interest […]
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CFPB Delays Effective Date for Dodd-Frank
by: Marissa Aquila Blundell, Esq.On Friday, November 16, 2012, the Consumer Financial Protection Bureau (CFPB) published a final rule which delays the effective date for compliance with the new mortgage disclosure rules included in Title XIV of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). The CFPB’s rule provides an exemption from compliance with […]
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MERS Annual Compliance Requirements
Special Announcement MERS Annual Quality Assurance Standards Compliance Report Summary of Requirements 1. All residential mortgage lenders who are registered MERS Members are required to comply with the MERS Quality Assurance Requirements. 2. Each Member must submit a Quality Assurance Plan by December 31, 2012 utilizing the proper template provided by MERSCORP […]
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Pennsylvania Implements Consumer Financial Protection Act
by: Lee Greenberg, Esq. The General Assembly of the Commonwealth of Pennsylvania recently revised the Banking Code of 1965 and the Department of Banking Code of 1933 through the enactment of House Bill 2368 and House Bill 2369. The new laws include several significant changes to various provisions of the respective banking codes, including the implementation […]
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National Flood Insurance Update
by: Anna DeSimoneNFIP Authorizes Grace Period for Flood Insurance Premium PaymentsNovember 7, 2012, the U.S. Department of Homeland Security issued a Service Bulletin regarding the National Flood Insurance Program (NFIP). The memorandum outlines the provisions for homeowners to quality for an extension of the Grace Period for payment of National Flood Insurance renewal premiums. Below […]
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Freddie Mac Issues Changes to ARMs and Affordable Home Programs
by: Michelle PetersCommentary regarding Freddie Mac Bulletin Number 2012-21 On October 16, 2012 Freddie Mac released Bulletin number 2012-21 regarding revisions to ARM requirements and provided updates regarding Home Possible Mortgages. The bulletin details ARM rate caps and qualification requirements that will help reduce the risk of payment shock to borrowers at the time of […]
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Fannie Mae Issues Additional Information on Quality Control
by: Anna DeSimoneOn October 19, 2012 Fannie Mae issued Lender Letter LL-2012-07, Fannie Mae’s Quality Control Process – Additional Information, along with Selling Guide Announcement SEL-2012-08, New Lender Selling Representations and Warranties Framework. The announcements state that, at the direction of the Federal Housing Finance Agency (FHFA) and jointly with Freddie Mac, the Enterprise is […]
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Freddie Mac Issues New Quality Control Framework
by: Anna DesimonePresident Today, Freddie Mac Announced Industry Letter, Quality Control and Enforcement Practice, along with Seller/Servicer Guide Bulletin 2012-22. The announcements expanded on the September 11, 2012 Industry Letter regarding quality control and enforcement requirements. The supplemental information pertains to repurchase timeframes, file requests, appeals, subsequent appeals and repurchase alternatives. The bulletin addresses the acceptable payment […]
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FHFA, Fannie Mae and Freddie Mac Launch New Rep and Warranty Framework
by Anna DeSimonePresident In an effort to increase transparency and certainty for lenders, the Federal Housing Finance Agency (FHFA) announced on September 11, 2012 that Fannie Mae and Freddie Mac launched a new representation and warranty framework. The ruling applies to conventional loans sold or delivered on or after January 1, 2013. Please refer to my […]
