Last month the Federal Emergency Management Agency (FEMA) published the revised NFIP Flood Insurance Manual, updated with program changes that will become effective October 1, 2014. The changes primarily impact those issuing FEMA policies, but contain information helpful to those obtaining FEMA policies. Among other items the manual shows where information was previously added in accordance with the Biggert-Waters Flood Insurance Reform Act of 2012, but removed to comply with provisions of the Homeowner Flood […]
Category: Lending Compliance
2013 HMDA DATA NOW AVAILABLE
On September 22, 2014 the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on mortgage lending transactions at 7,190 U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). Covered institutions include banks, savings associations, credit unions, and mortgage companies. The HMDA data cover 2013 lending activity, and include applications, originations, purchases and sales of loans, denials, and other actions related to applications. The data also include disclosure statements for […]
DISCRIMINATION AGAINST NATIVE AMERICANS
Are we in a time warp? Are we back in the 80’s? On September 15, 2014 the Department of Housing and Urban Development (HUD) announced a settlement agreement with U.S. Bank National Association, U.S. Bank subsidiary Red Sky Risk Services, LLC (formerly known as USB Lending Support Services, LLC), and one of U.S. Bank’s loan officers, resolving allegations that they refused to refinance the mortgage of a Native American couple in Belcourt, North Dakota, because […]
INTERAGENCY GUIDANCE ON HELOCS NEARING THEIR END-OF-DRAW PERIODS
On July 1, 2014 the federal financial institution regulatory agencies published guidance regarding the risk associated with Home Equity Lines of Credit (HELOCs) transitioning from their draw periods to full repayment. This is not a new issue. HELOCs have been part of product mix for financial institutions since the 1980s. Most HELOCs have a five or ten year draw period. During the draw period, a borrower has revolving access to unused amounts under a specified […]
ATR/QM POLL
Recently we polled our Compliance Master Group members on the Ability-to-Repay/Qualified Mortgages rules. There were no huge surprises, but we got a lot of confirmation of what we expected to see: Most creditors use a mix of ATR/QM options; The Small Creditor QM is the most popular ATR/QM option; Adopting the ATR/QM rules was a challenge, but did not reduce loan volume for most creditors; and Most creditors have not yet adopted Appendix Q, but […]