On March 23 Congress passed the Homeowner Flood Insurance Affordability Act. The Affordability Act revises certain sections of Biggert-Waters, eliminates or delays other sections and creates new rules. Section 13 of the Affordability Act is causing some controversy. It adds: The following exclusion to Subsection (c) of section 102 of the Flood Disaster Protection Act of 1973: (3) DETACHED STRUCTURES.—Notwithstanding any other provision of this section, flood insurance shall not be required, in the case
WHAT IS MISMO?
Category: HMDA, Lending Compliance, Regulation C
The Mortgage Industry Standards Maintenance Organization, (MISMO) is a not-for-profit subsidiary of the Mortgage Bankers Association (MBA). It is a developer of technology standards for both residential and commercial property transactions. By promoting improved data consistency, MISMO aims to reduce costs and increase transparency while promoting confidence in mortgages as an asset class for investors. MISMO develops and maintains a comprehensive set of standards and data points for all stages of the mortgage loan life
WHERE’S HMDA HEADED? PART 5 – OPERATIONAL IMPROVEMENTS
Category: CFPB, Dodd-Frank Act, FFIEC, HMDA, Lending Compliance, Regulation C
The Consumer Financial Protection Bureau (CFPB) wants to improve the collection, reporting and sharing processes for Home Mortgage Disclosure Act (HMDA) data. This effort has the potential to reduce the burdens on lenders; but in its short history the CFPB has not earned a reputation for taking action solely in the interest of financial institutions. Collection and Reporting Approximately 70 percent of all loans eventually sold to a Government-Sponsored Enterprise use the Uniform Loan Delivery Dataset
HUGE UDAAP PENALTY
Category: CFPB, Lending Compliance, UDAAP
The CFPB announced that Bank of America has agreed to pay $772 million in refunds and penalties for deceptive credit card practices. Please don’t stop reading just because the case involves a big bank and credit card issues. The deceptive practices in this case involved debt cancellation and identity theft monitoring products which may be a concern for banks of any size and for many products other than credit cards. A simple rule for deciding
WHERE’S HMDA HEADED – PART 4 EXPANDED INFORMATION FOR EACH LOAN OR APPLICATION
Category: CFPB, Dodd-Frank Act, HMDA, Lending Compliance, Regulation C
When Congress enacted the Dodd-Frank Act in 2010, it directed the Consumer Financial Protection Bureau (CFPB) to improve Home Mortgage Disclosure Act (HMDA) reporting. Under the current HMDA collection rules, covered lenders have to report certain residential mortgage information such as the type of loan, the census tract where the property is located, and the race and ethnicity of the borrower. Improving the kinds of information collected will make it easier to identify new consumer protection
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