I lot of people seemed to think that once the August 1 TRID deadline arrived life would be much easier. Well today is August 1, and the future doesn’t look any easier. TRID has been delayed until October 3, 2015; New interagency flood insurance regulations are effective, in large part, on October 1, 2015, with the new escrow rules unfolding on January 1, 2016; The new Military Lending Act regulations, which look like the real […]
Category: Flood Insurance
FLOOD RULE CONUNDRUM: DOES YOUR FINANCIAL INSTITUTION QUALIFY FOR THE SMALL LENDER EXCEPTION?
On June 22nd, the agencies (FRB, OCC, FDIC, NCUA, and FCA) issued a joint final rule to modify existing flood regulations. On June 24th, we issued an article discussing these new interagency flood rules (to access that article click here) that examined the three main elements of the final rule: detached structures, escrow provisions, and force placement. Since then we have received numerous questions relating to the small lender exception to the escrow portion of […]
JOINT AGENCIES ISSUE FINAL RULE ON FLOOD INSURANCE
The joint agencies (OCC, Federal Reserve Board, FDIC, Farm Credit Administration and NCUA) recently approved a final rule that modifies the regulation for loans secured by property located in a special flood hazard area. The final rule implements certain provisions that were established under the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) such as the requirement to escrow for flood insurance premiums on residential improved real estate securing a loan, as well as, an […]
PENDING LENDING ISSUES
Can we see the light at the end of the tunnel? Maybe faintly. Truth-in-Lending/RESPA Integrated Disclosures (TRID) – The biggest pending issue is the TRID rules that are effective August 1, 2015. Some vendors have delivered updates to loan origination software for testing. Policies, procedures, and training need to be completed. But it is appears likely that most lending institutions will complete all required tasks by the deadline. Some, like the banker I talked to […]
PROPOSED FLOOD INSURANCE REGULATIONS
The Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC), the Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA) (collectively, the Agencies) are proposing to amend their flood insurance regulations to implement certain provisions of the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA), which amends some of the changes to the Flood Disaster Protection Act of 1973 mandated […]