Archive

Thanks for supporting Compliance Reosurce this year. We want to congratulate you for surviving 2015, and we hope you have a wonderful year-end holiday season and a happy, healthy and prosperous 2016. Jack Amy Robin Kelly

Recently we received the following Holiday Greeting from one of our Compliance Master Group members and wanted to share it with all of you: Merry TRIDmas and a HMDA New Year. Is that politically correct?  

Two innocent looking disclosures, but who knows the evil that lurks within. Loan Estimate: Liability after Foreclosure Taking this loan could end any state law protection you may currently have against liability for unpaid debt if your lender forecloses on your home. If you lose this protection, you may have to pay any debt remaining even after foreclosure. You may want to consult a lawyer for more information. Regulation: Section 1026.37(m)(7) requires the Loan Estimate […]

Last week, the FDIC provided the industry with a Financial Institution Letter (FIL 43-2015) to detail what financial institutions can expect in terms of initial examinations after the October 3rd TRID implementation date.  The first blog article in this series regarding TRID exam expectations can be found here. The Financial Institution Letter came after the CFPB released in mid-September the updated examination procedures the Bureau will rely on to complete initial exams.  In July, Director […]

On September 21, 2015 the Consumer Financial Protection Bureau approved a final rule amending Regulation Z. The final rule revises the CFPB’s regulatory definitions of small creditor, and rural and underserved areas, for purposes of certain special provisions and exemptions from various requirements provided to certain small creditors under the Bureau’s mortgage rules. The final rule specifically addresses: Escrow requirements for higher-priced mortgage loans; Ability-to-repay/qualified mortgage requirements; and HOEPA requirements. Small Creditor – Loan Volume […]