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 […]
Tag: Dodd-Frank Act
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 […]
WHAT IS AN EFFECTIVE DATE?
Whenever federal financial institution regulatory agencies issue new final regulations they include an effective date. We have all seen, “The rule is effective January 10, 2014” or “The rule is effective for applications received on or after January 10, 2014,” but what does that mean. Apparently the term “effective date” means different things to different people. For financial institution regulatory agencies the term “effective date” apparently refers to the date by which a financial institution […]
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, […]
POINTS AND FEES – INDEX RATE FOR PERSONAL PROPERTY
When calculating points and fees §1026.32(b)(1)(i)(E and F) allow the creditor to exclude from the calculation up to two bona fide discount points under §1026.32(b)(1)(i)(E), or up to one bona fide discount point under §1026.32(b)(1)(i)(F), paid by the consumer in connection with the transaction, if certain conditions are met. When a loan is secured by personal property, such as a mobile home, the condition is that the interest rate without any discount does not exceed […]