A number of different federal lending compliance regulations use the term “manufactured home.” For example, the appraisal rules in Section 1026.35(c) of Regulation Z contain exemptions for both mobile home and manufactured homes, but the exemptions differ for one category of home versus the other. For HMDA and Regulation C lenders must gather and submit information regarding, among other categories, the property type. There seems to be much confusion regarding the definition of “manufactured home.”
HOME BORROWERS DON’T SHOP
Category: CFPB, Lending Compliance
The Consumer Financial Protection Bureau (CFPB) recently published a blog article reporting the results of their National Survey of Mortgage Borrowers. Key findings from the survey include: Almost half of consumers who take out a mortgage for home purchase fail to shop prior to application; that is, they seriously consider only a single lender or mortgage broker before choosing where to apply. The tendency to shop is somewhat higher among first-time homebuyers. The primary source
2015 LENDING COMPLIANCE THRESHOLDS
Category: CRA, HMDA, Lending Compliance, Regulation C, Regulation Z, Truth in Lending
Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2105 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.221 billion. The term “intermediate small bank” means a small
MATERNITY LEAVE – GUIDELINES
Category: Fair Housing
The previous parts of this article have documented the issue of maternity leave discrimination and the typical regulatory response to the problem. Now we focus on steps to avoid the problem. Underwriting guidelines should provide detailed instructions on the consideration and calculation of temporary leave income. Most investors have such guidelines in place. A typical set of guidelines for temporary leave income are contained in the Fannie Mae Selling Guide (Published December 14, 2014). The
MATERNITY LEAVE – THE CURE
Category: Fair Housing
In the first part of this article we explored the issue of maternity leave discrimination. This time we consider the typical cure imposed by regulators. Creditors have paid millions of dollars in damages; typically in the range of $20,000 to $30,000 per incident. In additional to paying damages, creditors are often required to implement revised policies and procedures and to conduct training. Policies It is common for a settlement agreement to require creditors, within thirty
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