Familial Status – Discrimination based on the presence or the anticipated presence of children under the age of 18. In my seminars I point out how unusual it is to see cases of family status discrimination. Most examiners don’t look for this problem and most lenders don’t engage in this type of discrimination. So imagine my surprise when HUD slammed a Houston-based mortgage lender with a big enforcement action for familial status discrimination. The lender
RULES AND ORDERS TO BE ENFORCED BY THE CFPB
Category: Dodd-Frank Act, Financial Reform, Lending Compliance
On May 31st the Consumer Financial Protection Bureau (CFPB) published the list of the rules and orders it will enforce beginning on the designated transfer date of July 21, 2011. The list includes the agencies transferring rules and orders to the CFPB. The CFPB will be very busy in the coming months, and probably for several years to come. Board of Governors of the Federal Reserve 1. 12 CFR Part 202—Equal Credit Opportunity Act (Regulation
The Federal Reserve Bank of Kansas City has an amazing free training resource for bank directors, aptly named Training for Bank Directors. The information is available at: https://www.bankdirectorsdesktop.org/training.cfm?m=01&l=01&s=1.htm. The computer based training includes approximately fifty modules covering the following topics: * What is a Bank? * Regulatory Structure * Regulatory Compliance * Bank Safety and Soundness * When Things Go Wrong The material is basic. You will not be granting PhDs in banking to directors
Recently we have received several inquiries from financial institutions regarding the new Mortgage Call Reports (MCRs) required by the Nationwide Mortgage Licensing System (NMLS). A MCR is required of a company that holds a state license or registration through the NMLS. Remember the SAFE Act requires all mortgage loan originators, both financial institutions and other mortgage lenders, to register with the NMLS. Financial institution MLOs merely have to register. Non-banks MLOs have to both get
Recently the Federal Reserve Board (FRB) requested comment on a proposed rule under Regulation Z that requires creditors to determine a consumer’s ability to repay a mortgage before making the loan and also establishes minimum mortgage underwriting standards. We already have a similar requirement for Section 32 mortgages, Section 35 mortgages (higher-priced mortgage loans), and for open-end credit. The requirement is being expanded to all consumer mortgage loans (except home equity lines of credit, timeshare
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