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How to Prepare for a Fair Lending Examination: Part III – Examination Results and Self-Assessment
by Margaret Wright, Esq. Assistant Vice President & Senior Counsel A lender’s understanding of the examination procedures established under the Interagency Fair Lending Examination Procedures is vital in establishing a valuable fair lending self assessment program. Following the same steps for self assessment as in a regulated fair lending examination is key to ensuring fair lending […]
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How to Prepare for a Fair Lending Examination: Part II – The Examination
by Margaret Wright, Esq.Assistant Vice President & Senior Counsel A lender’s understanding of the examination procedures established under the Interagency Fair Lending Examination Procedures is vital in establishing a valuable fair lending self assessment program. Following the same steps for self assessment as in a regulated fair lending examination is key to ensuring fair lending […]
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How to Prepare for a Fair Lending Examination: Part I – Examination Scope
Dear Reader, This newsletter article is the first of a three-part series on How to Prepare for a Fair Lending Examination. You’ll learn what to expect from an examiner and ways to complete a self assessment steps. Margaret carefully explains the rules published in August 2009 by the OTC, FDIC, Federal Reserve Board, OTS […]
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CFPB Considers Proposals Affecting Originator Compensation and Qualification
by Marissa Aquila Blundell, Esq.Sr. VP & General Counsel The Consumer Financial Protection Bureau (CFPB) has begun to publish press releases highlighting policies under consideration in advance of its issuing proposed rules. Based on the timelines mentioned by the CFPB in these press releases, it appears that the industry should expect the rule-making process, consisting of […]
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Fannie Mae Updates Servicers’ Payments of Homeowners Association & Condo Dues
by Carolyne MunyuiAssistant Vice President On April 11, 2012, Fannie Mae issued an Announcement (SVC-2012005) requiring servicers to protect the priority of the mortgage lien and to clear all liens for delinquent homeowners’ association (HOA) dues and condo assessments, on properties acquired through foreclosure or deed-in-lieu of foreclosure. The Policy changes specified in this Announcement […]
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Fannie Mae Updates Lender-Placed Property Insurance and Claims Processing
by Carolyne MunyuiAssistant Vice President On March 14 2012, Fannie Mae issued an announcement to update the Servicing Guide, on its policy regarding the use, coverage requirements, deductibles, carrier eligibility requirements & allowable reimbursable expenses for lender placed insurance. The Announcement (SVC-2-12-4) requires implementation no later than June 1, 2012. Servicers must obtain lender-placed coverage […]
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CFPB to Pursue Discriminatory Lenders
by Anna DeSimonePresident & Founder On April 18, 2012, the Consumer Financial Protection Bureau (CFPB) issued Bulletin 2012 -04 to provide guidance regarding compliance with the fair lending requirements of the Equal Credit Opportunity Act (ECOA). The CFPB stated it will use all available legal avenues, including disparate impact, to pursue lenders whose practices discriminate […]
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Fannie Mae Updates Delinquency and Default Management Requirements
by Carolyne MunyuiAssistant Vice President On April 25, 2012, Fannie Mae released the announcement No. SVC-2012-06 that describes policy changes under delinquency management and default prevention. The announcement provides an update and clarification as it applies to Fannie Mae HAMP modifications, Fannie Mae Standard modifications and directive or delegated modification programs in the following categories; […]
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New York Amends Laws for Mortgage Loan Originators
by Nicole Legere, Esq.Associate Counsel New York Banking Law Article 12-E governing mortgage loan originators (MLOs) was recently amended to conform to federal regulations. Pursuant to the federal SAFE Act, any state MLO licensing schemes that do not satisfy a minimum standard is preempted and HUD is charged with implementing a licensing scheme in those […]
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Rural Housing Service Clarifies Eligibility Guidelines for Refinancing
by Anna DeSimonePresident & Founder The Rural Housing Service (RHS) published Announcement #4635 on April 2, 2012 to provide updated instructions regarding the refinance feature of the Single Family Housing Guaranteed Loan Program (SFHGLP). The objective of the refinance feature is to assist responsible homeowners in achieving more favorable terms by transferring their present financing […]
