“Can we renew a loan which is covered by force placed insurance?” Variations on this question have come up several times in recent seminars I have conducted. The answer to the question is no. If a borrower refuses to obtain flood insurance coverage as a condition of obtaining a loan, the loan is deficient and may not be made. Force placement of coverage is designed for use at any time during the loan in uninsured
Last month all of the federal financial institution regulatory agencies showed up at Independent Community Bankers of America’s national convention and told those in attendance what they wanted to hear. “The future of community banking is a major priority.” “We have undertaken a review of the history of community banking.” And my favorite, “Where it makes sense to treat community banks differently from larger institutions, we have pledged to consider doing so.” Not a single
Over the years many of you have heard me discuss the rescission rules contained in Regulation Z. I always explained that if the lender screws up and fails to give the notice, fails to give a timely notice, fails to give the correct notice, fails to properly complete the notice, fails to wait three days before distributing the form, fails to give timely and accurate TIL disclosures, or makes any one of several other errors
NEW FEDERAL REGISTRY RESOURCE CENTER OPENS
Category: MLO Registration, Mortgage Loan Originator, SAFE Act
On April 2, 2012 the Nationwide Mortgage Licensing System & Registry opened a new Federal Registry Resource Center. Everything needed for Federal Registration is available in the new center, including all Quick Guides, instructions and reference materials that pertain to Federal Registration. The new Center is available at: https://fedregistry.nationwidelicensingsystem.org/Pages/default.aspx
CFPB GUIDANCE ON LOAN ORIGINATOR COMPENSATION
Category: CFPB, Dodd-Frank Act, Financial Reform, Regulation Z, Truth in Lending, Uncategorized
Better late than never! Yesterday the Consumer Financial Protection Bureau provided long-awaited guidance (CFPB Bulletin 2012-02) on the Regulation Z Loan Originator Compensation rules that were effective in April 2011. The Compensation Rules provide that no loan originator may receive (and no person may pay to a loan originator), directly or indirectly, compensation that is based on any terms or conditions of a mortgage transaction. The Commentary to the Regulation clarifies that compensation includes salaries,
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