We received some solid feedback to our recent article Compliance Review/Audit Considerations for 2014. Several readers thanked us for the article. Two reported that the 2014 review/audit was headed for “business as usual” until they inquired about the scope of the proposed review/audit and discovered Dodd-Frank was not included. One of the bankers is switching to another company for their 2014 and future reviews, reporting, “We have lost confidence in … (the name of their […]
Category: Lending Compliance
PROVIDING THE LIST OF HOMEOWNERSHIP COUNSELORS
On November 8 the Consumer Financial Protection Bureau (CFPB) released a tool that provides an easy-to-use method of providing the required list of homeownership counseling organizations. Creditors can provide the list made available through the CFPB tool or may develop their own lists using the same HUD data that the CFPB uses in the tool. Some loans origination software systems (LOS) have not completed links in their software to automatically download the lists. As an […]
COMPLIANCE REVIEW/AUDIT CONSIDERATIONS FOR 2014
Compliance audits for 2014 are not business as usual. We have all been inundated by the volume of changes. There is confusion regarding when examiners will be ready to begin compliance examinations for the new and revised requirements and how intense those examinations will be. The regulators have indicated that “… oversight of the new mortgage rules in the early months will be sensitive to the progress made by institutions that have been squarely focused […]
REVISED COMPLIANCE BROCHURE AND BOOKLETS
On January 6, 2014 the Consumer Financial Protection Bureau (CFPB) published three revised consumer publications, including a consumer information brochure and two booklets required under the Real Estate Settlement Procedures Act (RESPA), Regulation X, the Truth in Lending Act (TILA), and Regulation Z. These publications are titled: (1) What You Should Know About Home Equity Lines of Credit (HELOC Brochure); (2) Consumer Handbook on Adjustable-Rate Mortgages (CHARM Booklet); and (3) Shopping for Your Home Loan, […]
JUNE 1, 2014 NATIONAL FLOOD INSURANCE PROGRAM CHANGES
Recently the Federal Emergency Management Agency (FEMA) published a summary of the changes to the National Flood Insurance Program that will be effective on June 1, 2014. The changes result from the Biggert-Waters Flood Insurance Reform Act of 2012. The summary provides an excellent overview of some of the fun that is ahead of us. A copy of the notice is available here. Notice to Compliance Masters Group Members – The upcoming changes to […]