[jholzknecht]

During our January 10th Compliance Master Group Meetings we received a number of comments on the status of loan origination software.Comments include:
• Laser Pro has part of the updates, but not the part for small lenders.
• Laser Pro’s section concerning small lenders should be released on 1/24/14.
• We have same problem with Laser Pro and the Variable HELOCs
• Our Compliance One Software cannot retrieve the counseling agency lists until July 2014. They have a workaround for us of a disclosure telling the borrowers where to go to get that information. [Editors Note: Regulation X requires you to provide the list whether your software is capable of providing the list or not.]
• We use Compliance One for our HELOC originations. We are pulling the disclosure of counseling agencies direct from the CFPB site.
• LaserPro currently cannot pull the homeownership counseling list. We have procedures in place to manually pull the listing from the CFPB website and provide to applicants. It is a manual process for now.
• Calyx is testing for QM. We have not tested other items yet.
• Laser Pro doesn’t allow for 3.50% calculation for Higher priced loans for 1st and 2nd mortgages for small lenders. It also has a warning if the DTI is over 43% on small lenders
• We’re still testing – Creative Visions had some issues that one of my associates is working through – I don’t have the specifics. We also have LaserPro – and that just was updated, don’t know yet just how its working

[Bankoftn]

Note to the editors note above in the 4th bullet: The CFPB released an interpretive rule on 11/8/13 that allows for a temporary method of compliance with providing the Homeownership Counseling Rules. For a “temporary” fix (specific expiration was not given in the rule) we can comply by providing a specifically worded disclosure that directs the consumer to the appropriate website. The intent of the interpretive rule appears to be to allow loan origination software companies to get their programming complete, so I would not use this alternative method of disclosure if my LOS is capable of generating the list. Here is the link to the interpretive rule:

https://files.consumerfinance.gov/f/201311_cfpb_bulletin_homeownership-counseling-list-requirements.pdf

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