The CFPB recently issued its strategic plan for fiscal years 2018-2022, with a heavy reliance on technology and data to make sure the industry is complying with its various rules and regulations.The document articulates a handful of the bureau’s goals for the next five years, and then breaks out the various objectives by which it intends to reach those goals, along with strategies to attain those objectives.The CFPB’s most relevant goal for lenders, from a supervisory and compliance point of view, is to prevent financial harm to consumers while promoting good practices that work for consumers, responsible providers, and the economy as a whole. One objective the agency plans to pursue is to supervise institutions to foster compliance ...
The CFPB recently published an updated iteration of its small-entity compliance guide for the integrated disclosure rule under the Truth in Lending Act and the Real Estate Settlement Procedures Act, or TRID.The bureau updates this guide periodically to reflect finalized clarifications to the rule which affect guide content, as well as administrative updates. This latest version reflects the final rule that was issued July 7, 2017, and published Aug. 11, 2017. Among the revisions incorporated is the change regarding disclosure of specific seller credits (Section 13.10). There are also numerous updates to incorporate changes and clarifications from the July 7, 2017 amendments to the TILA-RESPA final rule, including: requirements and guidance on current requirements for tolerances in the good ...
The CFPB has come out with the second version of its Home Mortgage Disclosure Act (Regulation C) small-entity compliance guide. This iteration reflects a variety of changes to the bureau’s HMDA rule that were issued in August 2017 and published on Sept. 13, 2017. The HMDA rule changes the types of financial institutions that are subject to Regulation C; the types of transactions that are subject to the regulation; the data that financial institutions are required to collect, record and report; and the processes for reporting and disclosing HMDA data. According to Richard Andreano, a partner in the Washington, DC, office of the Ballard Spahr law firm, “One of the main changes incorporated in the revised guide is the temporary ...
It looks like the CFPB might be contemplating new disclosures for Home Equity Conversion Mortgages, otherwise known as reverse mortgages. The agenda for the Nov. 2 meeting of the bureau’s Consumer Advisory Board, which was posted online recently, indicates the panel “will discuss Know Before You Owe: Reverse Mortgages, financial well-being, trends and themes, and payday, vehicle title, and certain high-cost installment loans.” The use of the phrase “Know Before You Owe” suggests a new disclosure regime for reverse mortgages could be in the offing. The CAB meeting announcement also indicates that written comments will be accepted from interested members of the public. They should be sent to CFPB_CABandCouncilsEvents@cfpb.gov at least seven days before the meeting. “The comments will be ...
Complaints consumers made to the CFPB about their mortgages fell in every single category tracked during the third quarter of 2017, according to a new analysis and ranking by Inside the CFPB, further evidence of the recovery underway in the market. In fact, the sole category that saw an increase on a year-over-year basis was the loan application/ origination grouping, which was still at elevated levels after a surge in the first quarter, possibly due to issues associated with the implementation of the integrated disclosure rule. Total criticisms fell by 21.2 percent from the second quarter to the third, and by 27.7 percent from the third quarter of 2016 to the third quarter of 2017. [With exclusive data] ...
Republicans Take Issue With Fannie/Freddie QM Exemption. Some Congressional Republicans recently expressed concerns about the special treatment that loans eligible for sale to the government-sponsored enterprises currently enjoy under the CFPB’s qualified mortgage standards.... CFPB Updates HMDA Implementation Materials, Filing Instructions Guide. As part of its effort to support the industry’s adoption of the CFPB’s recently issued 2017 Home Mortgage Disclosure Act final rule, the bureau has updated the chart titled: Collection and Reporting of HMDA Information about Ethnicity and Race.... Other Federal Regulators Issue Designated Key HMDA Data Fields List. The Federal Reserve, the Federal Deposit Insurance Corp., and the Office of the Comptroller of the Currency last week jointly issued ...
Ginnie Mae issuers rode a wave of purchase-mortgage lending to deliver $120.46 billion of forward mortgages during the third quarter of 2017, the highest three-month volume for the year, according to a new analysis and ranking by Inside FHA/VA Lending. Third-quarter volume was up 9.6 percent from the April-June cycle. The data excluded FHA reverse mortgages and loan amounts are truncated in Ginnie’s mortgage-backed securities disclosures. Without those limitations, total Ginnie MBS issuance rose 9.5 percent to $123.37 billion in the third quarter. Purchase mortgages were the engine behind the growth. Ginnie issuers securitized $85.35 billion of purchase loans in the third quarter, falling just short of the record $85.41 billion set in the third quarter of last year. Although most Ginnie purchase loans (58.7 percent) were FHA loans, the biggest increase was in such loans guaranteed by the ... [Charts]
Ginnie Mae and the VA this week officially announced a joint-agency task force to deal with the loan-churning problem that is triggering faster prepayments in Ginnie mortgage-backed securities pools. Specifically, the task force will scrutinize aggressive and misleading refinancing offers and address loan churning and repeated refinancings. It will also examine critical issues, data and lender behaviors related to refinancing loans, as well as determine the kind of policy and program changes agencies should make to ensure VA refi loans do not pose an undue risk or burden to vets and taxpayers. Both the VA and Ginnie Mae programs work best when market participants use them to provide a benefit to VA borrowers and, ultimately, lower vet’s costs, officials said. The task force has begun examining data and information to ensure refi loans provide net tangible benefits to veteran-borrowers. In addition, the ...
The FHA has updated its guidelines for Home Equity Conversion Mortgage for Purchase (H4P) loans to allow lenders to accept loan applications from borrowers without requiring a certificate of occupancy, as well as prior to completion of HECM counseling. The change follows the Sept. 19 effective date of the HECM final rule, which the Department of Housing and Urban Development released earlier this year. The final rule codifies the many policies that are now in place for originating and servicing reverse mortgages, including H4P requirements. According to the revised guideline, an FHA lender may take an initial HECM loan application either prior to or after the completion of HECM counseling. Also, previously, H4P properties were eligible for FHA insurance only when construction was completed and when the local jurisdiction issued a certificate of occupancy or its equivalent, confirming the ...
The Department of Housing and Urban Development is discontinuing its quarterly newsletter, Lender Insight, with the implementation of FHA’s Loan Review System. The change is aimed at improving both FHA’s and lenders’ quality-control and risk-management operations. HUD will be publishing a quarterly Loan Review Summary Report to provide a snapshot of the results of FHA’s quality-control review of mortgage originations over the preceding 12 months. According to HUD, the report will include only underwritten loans that were subject to a post-endorsement technical review. It does not include the results of lenders’ self-reports or any other loans that were reviewed as part of a lender examination, the agency said. The report will show the initial rating of all loans, the updated rating six months from the end of the review period, and a final rating. The “final” rating is subject to change as long as ...