The Outlook for Mortgage Lenders and Brokers - PowerPoint PPT Presentation

1 / 33
About This Presentation

The Outlook for Mortgage Lenders and Brokers


The Outlook for Mortgage Lenders and Brokers and the Impact of Federal Lending Regulations Maryland Association of Mortgage Professionals 2013 Annual Conference – PowerPoint PPT presentation

Number of Views:324
Avg rating:3.0/5.0
Slides: 34
Provided by: mdmtgpros


Transcript and Presenter's Notes

Title: The Outlook for Mortgage Lenders and Brokers

The Outlook for Mortgage Lenders and Brokers and
the Impact of Federal Lending Regulations Marylan
d Association of Mortgage Professionals 2013
Annual Conference March 13, 2013 Jim
CFPB Regulatory Authority
  • In January the CFPB issued 7 Final Rules
  • January 10
  • Ability to Repay (TILA)
  • High-Cost Mortgages (HOEPA) Homeownership
    Counseling Amendments to TILA RESPA
  • Escrow Accounts for Higher-Priced Loans (TILA)
  • January 17
  • Mortgage Servicing under TILA RESPA
  • January 18
  • Appraisals for Higher-Priced Mortgage Loans
  • ECOA Appraisals Requirements
  • January 20
  • Loan Originator Compensation (TILA)

Ability to Repay Final Rule
  • Scope Overview
  • Applies to all consumer credit transactions
    secured by a dwelling
  • Except HELOCs, investment properties (business
    purpose loans), timeshare plans, reverse
    mortgages, temporary or bridge loans of 12
    months or less, or construction-to-permanent loan
    with a construction phase of 12 months or less
  • Creditors must make a reasonable good faith
    determination, at or before consummation, that
    the consumer will have a reasonable ability to
    repay the loan according to its terms
  • 3 ways to comply
  • General ATR Option meet 8 general underwriting
  • Qualified Mortgage (QM) Option either a safe
    harbor from or a rebuttable presumption of
    compliance with ATR factors
  • Includes Temporary QM Balloon QM
  • Refinance of a non-standard mortgage into a
    standard mortgage
  • Effective Date January 10, 2014

Ability to Repay Final Rule
  • Penalties
  • TILA contains severe penalty provisions for
    failure to consider Ability to Repay for
    violation of LO compensation qualification
  • Consumer may be able to recover special statutory
    damages equal to sum of all finance charges
    fees paid by the consumer, unless creditor
    demonstrates failure to comply is not material
    (in addition to actual damages, statutory
    damages, and court costs attorneys fees)
  • Statute of limitations 3 years from date of
  • Defense by recoupment or set-off in a foreclosure
    action by the creditor, any assignee of the
    creditor, or anyone acting as servicer on behalf
    of the holder of the loan
  • No time limit on use of defense, but consumer
    cannot recover more than first 3 years of finance
    charges fees plus actual damages fees
    (including reasonable attorneys fees)
  • Recordkeeping will be crucial for evidencing

Ability to Repay Final Rule
  • General ATR vs. QM
  • General ATR
  • Must consider verify 8 specific underwriting
    factors to make a reasonable good faith
    determination of ability to repay using
    reasonably reliable third-party records
  • Creditors are given flexibility in developing
    their own underwriting standards changing those
    standards over time
  • But must show determination was reasonable in
    good faith
  • QM
  • Provides liability protection either a safe
    harbor from or a rebuttable presumption of
    compliance with the 8 General ATR factors
  • But a QM must satisfy product feature
    requirements, stricter underwriting standards
    points fees limitation
  • Rule adds Appendix Q to Regulation Z
  • Sets forth specific underwriting requirements on
    what must be considered for each factor how
    factors are used to calculate DTI ratio
  • Based on FHA Handbook 4155.1 manual underwriting

Ability to Repay Final Rule
  • General ATR Option
  • Must consider verify 8 ATR underwriting factors
  • Borrowers current or reasonably expected income
    or assets, except for value of the dwelling that
    secures the loan
  • Borrowers current employment status (assuming
    creditor relies on employment income in
    determining repayment ability)
  • Borrowers monthly payment on the covered
    transaction, calculated in accordance with the
    ATR final rule
  • Borrowers monthly payment on any simultaneous
    loan the creditor knows or has reason to know
    will be made, calculated in accordance with the
    ATR final rule
  • Borrowers monthly payment for mortgage-related
  • Borrowers current debt obligations, alimony and
    child support
  • Borrowers monthly debt-to-income ratio (DTI) or
    residual income, calculated in accordance with
    the ATR final rule
  • Borrowers credit history

Ability to Repay Final Rule
  • General ATR Option
  • More flexible underwriting standards than QM
  • Income or assets need only consider what is
    necessary to support a determination that the
    consumer can repay the loan
  • Verify using third-party records that provide
    reasonably reliable evidence of the borrowers
    income or assets (e.g., copies of tax-returns,
    W-2s, payroll statements, employer records)
  • Employment status may be full-time, part-time,
    irregular, etc. and may be verified orally if
    creditor makes a written record of the
  • Monthly payment on the covered transaction any
    known simultaneous loans must be calculated using
    the fully indexed rate or any introductory
    interest rate, whichever is greater and monthly,
    fully amortizing payments that are substantially
  • Monthly payment for mortgage related obligations
    includes recurring payments such as property
    taxes, MIP, HOAs, etc.
  • Current debt obligations creditor has
    significant flexibility to consider debt in light
    of attendant facts circumstances, including if
    the obligation is likely to be paid off soon
    after consummation

Ability to Repay Final Rule
  • General ATR Option (continued)
  • More flexible underwriting standards than QM
  • DTI Creditors have discretion to determine the
    appropriate ratio in making a reasonable good
    faith ATR determination
  • May consider compensating factors such as finding
    ATR despite a higher DTI in light of borrowers
    other assets
  • Credit history does not specify which aspects of
    credit history must be considered or how aspects
    should be weighed
  • Not required to obtain or consider a consolidated
    credit score
  • Evidence that determination was reasonable in
    good faith
  • Length of time a borrower successfully makes
    timely payments without modification or
  • Underwriting standards adopted by the creditor
    how it was applied to the facts circumstances
    of the loan
  • Standards were based on statistically sound
    models, historically resulted in low rates of
    default, applied consistently, etc.
  • Commentary emphasizes that whether a decision was
    reasonable in good faith will be highly
    individualized specific to the transaction

Ability to Repay Final Rule
  • QM Option
  • Concern about availability affordability of
    credit led to QM standard
  • QMs must meet the following requirements
  • Product features
  • Provide regular periodic payments
  • Not include negative amortization, interest-only
    or balloon features (except for balloon QM)
  • Loan term of 30 years or less
  • Underwriting requirements
  • Consider and verify borrowers current or
    reasonable expected income or assets current
    debt obligations in accordance with Appendix Q
  • DTI not to exceed 43 calculated using Appendix Q
  • Monthly payments calculated based on maximum
    interest rate that may apply during first 5 years
    of the loan periodic principal interest based
    on such interest rate
  • Points fees not exceeding 3 of the total loan
    amount of 100,000 or more, with greater limits
    for smaller loans
  • 60,000 - 99,999 3,000 (indexed for
  • 20,000 - 59,999 5
  • 12,500 - 19,999 1,000 (indexed for
  • Less than 12,500 8

Ability to Repay Final Rule
  • QM Option Underwriting Requirements
  • Appendix Q sets forth what income debt
    creditors must consider when calculating the DTI
  • Income can only be used if it comes from a
    source that can be verified, is stable, and will
    continue (income must be reasonably expected to
    continue for at least the first 3 years of
  • Standards on how to consider employment income
    non-employment income, such as
  • Overtime bonus only if received for the past 2
    years will likely continue (creditor must
    create an earnings trend)
  • Part-time seasonal if uninterrupted for past 2
    years to continue
  • Alimony, child support trust income only if
    payments are likely to be consistent for first 3
    years of mortgage (with strict documentation
  • Stricter rules on how to analyze tax
    returns/forms records
  • Employment must verify for most recent 2 full
    years borrower must explain any gaps
  • Must analyze the probability of continued
    employment by examining past record,
    qualifications, training, education, etc.

Ability to Repay Final Rule
  • QM Option Underwriting Requirements (continued)
  • Appendix Q sets forth what income debt
    creditors must consider when calculating the DTI
  • Debt standards on how to consider
  • Recurring obligations (e.g., revolving accounts,
    alimony, child support)
  • Monthly payments on revolving or open-end
    accounts included regardless of balance
  • Debts of less than 10 months included if amount
    of debt affects ability to pay during months
    after closing
  • Contingent liabilities (e.g., assumptions,
    cosigned obligations)
  • Projected obligations debt payments to begin or
    come due within 12 months of closing (e.g.,
    student loan, balloon payment)
  • DTI calculation cannot exceed 43
  • Must include monthly mortgage-related obligations
    simultaneous loans that creditors knows or has
    reason know about at or before consummation for
    the current transaction

Ability to Repay Final Rule
  • QM Option 3 Points Fees Cap
  • Points fees includes, if known at or before
  • Finance charge items other than interest
  • Real estate-related fees paid to lender,
    originator, or affiliate of either normally
    excluded from the finance charge (e.g., fees for
    title insurance, appraisal fees, credit report
  • Third party settlement agent fees if the creditor
    requires the service or charge, or retains a
    portion of the charge
  • Points charged to consumer to offset loan-level
    price adjustments
  • Credit insurance, debt cancellation premiums
    payable at or before consummation
  • Loan originator compensation (including employee
    LOs), paid directly or indirectly by a consumer
    or creditor that can be attributed to that
    transaction at the time the interest rate is set

Ability to Repay Final Rule
  • QM Option 3 Points Fees Cap
  • Points fees does not include
  • Third-party charges not retained by the creditor,
    originator or an affiliate of either (except
    otherwise included mortgage/credit insurance
    premiums real estate related fees)
  • Government mortgage insurance or guarantee fees
  • PMI payable after closing the portion of the
    up-front PMI premium that is not in excess of FHA
    standards if the premium is refundable on a pro
    rata basis automatic when loan is paid in full
  • Bona fide discount points that are knowingly paid
    to reduce the rate actually reduces the rate
    consistent with established industry practices,
    limited to
  • 2 points if undiscounted rate does not exceed the
    APOR by more than 1 percentage point
  • 1 point if undiscounted rate does not exceed the
    APOR by more than 2 percentage points

Ability to Repay Final Rule
  • Temporary QM
  • Because of the fragile state of the mortgage
    market, CFPB provided for a second, temporary
    category of QMs with more flexible underwriting
  • Temporary QM must
  • Satisfy the general QM criteria for regular
    periodic payments, maximum 30 year term, and 3
    points fees limit)
  • Satisfy the underwriting criteria of/eligible for
    purchase, insurance or guarantee by
  • Fannie Mae/Freddie Mac while they operate under
    Federal conservatorship or receivership or
  • Temporary QM will expire on the earlier of
  • Date the Federal agency issues its own QM rules
  • After 7 years (January 10, 2021)

Ability to Repay Final Rule
  • Special Small Creditor Portfolio Balloon QM
  • Standard definition of QM excludes loans with
    balloon payments
  • Exception for small creditors in
    rural/underserved areas
  • Less than 2 billion in assets, originated more
    than 50 of transactions in rural or underserved
    areas, but fewer than 500 total (with affiliates)
  • Loan generally cannot be sold, assigned, or
    transferred (unless 3 years after consummation or
    to another small creditor)
  • Balloon QM Requirements
  • Satisfy the standard QM requirements except for
    prohibitions on balloon payments deferment of
  • Consider verify current or reasonably expected
    income/assets, current debt obligations
    DTI/residual income
  • Determine consumer can make monthly mortgage
    payments mortgage-related obligations excluding
    the balloon payment
  • Must have substantially equal scheduled payments
    calculated using an amortization schedule that
    does not exceed 30 years
  • Loan term of 5 years or more
  • Fixed rate only

Ability to Repay Final Rule
  • QM Liability Protection
  • Safe Harbor if QM is not a higher-priced
  • APR does not exceed the APOR (Average Prime Offer
    Rate) by 1.5 or more percentage points (3.5 or
    more for junior lien)
  • Borrower can always challenge whether loan
    actually met the QM standards (i.e., points
    fees test, compliance with Appendix Q)
  • Rebuttable Presumption if QM is a higher-priced
  • APR exceeds the APOR by 1.5 percentage points
    (3.5 or more for junior lien)
  • Borrower can rebut presumption by showing
    creditor did not make a reasonable, good faith
    determination of repayment ability because
    consumers income, debt, alimony, child support
    monthly payments would leave insufficient
    residual income or assets to meet living expenses
    other non-debt obligations creditor was aware
  • But the longer borrower is able to pay, less
    likely able to rebut
  • Borrower can again always challenge whether loan
    met QM standards

Ability to Repay Final Rule
  • Concurrent Proposal
  • CFPB requested comments on the following
  • Inclusion of LO compensation in points fees
    (proposes alternative calculation methods to
    eliminate double counting or over-inclusion)
  • Raising the APR-APOR triggers for balloon loan
    QMs to allow more to reach safe harbor
  • New QM for smaller creditors that hold mortgages
    in portfolio
  • Proposed exemptions for Federal GSE refinancing
    programs, Homeownership Stabilization
    Foreclosure Prevention programs certain
    non-profit lenders
  • Comments were due Feb. 25, 2013

Ability to Repay Final Rule
  • Refinance Non-Standard Mortgage into Standard
  • Exempt from general ATR requirements if
  • New creditor is current holder or servicer of the
    non-standard loan
  • New monthly payment is materially lower
  • Creditor receives application no later than 2
    months after non-standard mortgage has recast
  • Consumer has made no more than one 30-day late
    payment in preceding 12 months no late payment
    in preceding 6 months
  • Creditor must consider whether the consumer is
    likely to default on existing non-standard
    mortgage when the loan is recast whether
    standard mortgage would likely prevent consumers
  • Non-standard mortgage an ARM with an
    introductory fixed rate for a period of 1 year or
    longer, an interest only loan, or a negative
    amortization loan
  • Standard mortgage
  • Provides for regular payments cannot have
    negative amortization, interest-only or balloon
    payment features
  • Fixed interest for first 5 years term cannot
    exceed 40 years
  • 3 points fees cap no cash out

Ability to Repay Final Rule
  • Prepayment Fee Restrictions
  • Covered transactions cannot include prepayment
    fees unless
  • Fee is otherwise permitted by law APR cannot
    increase after consummation
  • Loan is a QM (standard, temporary, or balloon)
    with a safe harbor (i.e., loan is not
  • Fee cannot apply after 3rd year following
  • Must not exceed 2 of outstanding loan balance
    prepaid during first 2 years after consummation
  • Must not exceed 1 during 3rd year after
  • If lender offers loan product with prepayment
    fee, then must also offer an alternative with
    similar features without prepayment fee
  • May not structure loan as open-end to circumvent
  • Must document compliance that alternative was
  • Recordkeeping Requirements
  • Records must be kept for 3 years after
  • Though records should be retained beyond because
    defense to foreclosure claims have no statute of
  • Actual paper records not required, as long as
    records can be reproduced

LO Compensation Final Rule
  • Loan Originator Standards/Compensation under TILA
  • Effective Jan. 10, 2014
  • Effective June 1, 2013 for prohibition on
    mandatory arbitration financing of credit
  • Generally keeps 3 basic principles of the current
  • No compensation based on a transactions terms or
    a proxy (fixed percentage of amount of credit
    extended is allowed)
  • No dual compensation
  • No steering
  • Loan Originator definition is expanded to
    include referring a consumer to a loan originator
    through directed actions that can affirmatively
    influence the consumer
  • The term does not include a person that performs
    purely administrative or clerical tasks, real
    estate brokers unless compensated by a creditor
    or loan originator, servicer employees or
    contractors for loan modifications, or seller
    financers that meet certain criteria (no more
    than 3 properties a year, not a contractor, etc.)
  • Violations are subject to same TILA penalties as
    Ability to Repay

LO Compensation Final Rule
  • Payments Based on Loan Terms or a Proxy for Loan
  • Maintains existing prohibition on compensation
    based on a term of a transaction or a proxy for a
  • Clarifies the definition of a proxy to focus on
  • The factor consistently varies with a transaction
    term over a significant number of transactions,
  • The loan officer has ability, directly or
    indirectly, to add, drop or change the factor in
    originating the transaction
  • Defined Contribution Plans
  • Allows for profit-sharing and bonus plans if it
    is not based on the terms of the individual
    originators transactions AND
  • Compensation paid in the aggregate does not
    exceed 10 of the originators total compensation
    during the time period the non-deferred profits
    based compensation is paid OR
  • Originated 10 or fewer transactions during the
    previous 12 months
  • Allows for contributions to designated
    tax-advantaged plans if it is not based on the
    terms of the individual originators transactions
    AND it is one of the enumerated plans in the rule
    that meets IRS requirements (annuity plans,
    simple retirement accounts, etc.)

LO Compensation Final Rule
  • Pricing Concessions
  • Permits decrease in originator compensation to
    defray the cost of an unforeseen increase in an
    actual settlement cost over an estimated
    settlement cost disclosed to the consumer or an
    unforeseen actual settlement cost not disclosed
    to the consumer
  • Dual Compensation
  • LO cannot receive compensation from both the
    consumer the creditor
  • Allows mortgage brokerage firms paid by the
    consumer to pay commissions to their individual
    brokers, so long as commission is not based on
    transaction terms
  • Requires that parties closely track document
    each payment
  • Payments from the consumer to the LO include
  • Payments to the LO from loan proceeds
  • Payments to the LO pursuant to an agreement by a
    person other than creditor or its affiliates
    (i.e., non-affiliated seller or homebuilder)
  • Payments from the consumer to the LO do not
  • Payments derived from an increased interest rate
  • Funds from the creditor to reduce the consumers
    settlement charges, including origination fees
    paid by a creditor to the LO
  • Payments to the creditor, whether paid directly
    by the consumer or out of loan proceeds

LO Compensation Final Rule
  • Upfront Points Fees
  • Creditors can charge consumers upfront points
  • CFPB declined to put the proposed No-Point,
    No-Fee loan option requirement in the Final Rule
  • No Point Banks
  • CFPB briefly indicated that it believes there are
    no circumstances under which point banks are
  • Record Keeping Requirements
  • Creditors are required to maintain records
    sufficient to evidence all compensation paid to
    an originator the compensation agreement that
    governs those payments for 3 years after the date
    of payment
  • LO organizations have the same requirements plus
    records of all compensation received from
    creditors, consumers or another party
  • Personal Liability for Loan Originators for
  • Limited to the greater of actual damages or 3
    times the total amount of direct or indirect
    compensation received, plus costs of the action
    reasonable attorneys fees

LO Compensation Final Rule
  • Originator Qualification Screening Standards
  • Individual loan originators their employers
    must be qualified
  • Employers must ensure their loan originator
    employees are licensed or registered under the
    SAFE Act where applicable
  • Employers of loan originators not required to be
    licensed under the SAFE Act must ensure that loan
    originators meet character, fitness and criminal
    background check standards equivalent to those in
    the SAFE Act
  • Requires the loan originator receive appropriate
  • Requires individual loan originators their
    employers names license or registration
    numbers to be included on the following mortgage
    loan documents
  • Credit application
  • Note or loan contract
  • Security instrument

LO Compensation Final Rule
  • Additional Requirements
  • More Steering Provisions in the Future
  • Dodd-Frank requires the CFPB to prescribe
    regulations to prohibit certain kinds of
    steering, abusive or unfair lending practices,
    mischaracterization of credit histories or
    appraisals discouraging consumers from shopping
  • CFPB to address such regulations in a future
  • Ban on Mandatory Arbitration Clauses
  • Contract cannot include terms that require
    arbitration or any other non-judicial procedure
    to settle claims arising from the transaction
  • Contract cannot be interpreted to bar a consumer
    from bringing a claim
  • Restriction on Financing of Credit Insurance
  • Creditors are not permitted to finance, directly
    or indirectly, any premiums or fees for credit
    insurance in connection with a covered
  • Does not apply to credit insurance paid in full
    on a monthly basis or credit unemployment
    insurance where premiums are reasonable, paid
    pursuant to a separate contract, not paid to an
    affiliate of the creditor the creditor receives
    no compensation on it

High-Cost Mortgage Final Rule
  • Final Rule for High-Cost Mortgage Homeownership
  • Expands HOEPA coverage (High-Cost Mortgage)
  • To include purchase-money loans open-end credit
  • Reverse mortgages remain excluded
  • Revisions to HOEPA triggers
  • APR Test Loan APR exceeds the APOR by
  • 6.5 percentage points for first-lien mortgages
    (8.5 if dwelling is personal property total
    transaction amount is less than 50,000)
  • 8.5 percentage points for subordinate lien
  • Points Fees Test Loan points fees exceed 5
    of the total loan amount, or 8 for loans below
    20,000 or
  • Prepayment Penalty Test Loan provides that
    creditor may charge
  • a prepayment penalty more than 36 months after
    loan consummation or account opening or
  • penalties that exceed more than 2 of the amount
  • New restrictions on HOEPA
  • Ban fees for modifying loans, cap late fees and
    restrict the charging of fees for payoff
  • Require housing counseling before taking out a
    high-cost mortgage
  • New general RESPA requirement list of
    homeownership counseling organizations must be
    provided within 3 business days of application
  • Effective Date Jan. 10, 2014

Appraisals for Higher-Priced Loans
  • Final Rule on Appraisals for Higher-Priced
    Mortgage Loans
  • Final Rule Amends TILA/Reg Z
  • Effective Date Jan. 18, 2014
  • Before making higher-priced mortgage loan
    creditors must
  • Obtain a written appraisal performed by a
    certified appraiser and based on a physical
    inspection of a propertys interior
  • Provide applicant a statement regarding the
    purpose of the appraisal at time of application
    and a free copy of any written appraisals
    obtained 3 business days prior to closing
  • Obtain a second written appraisal at no cost to
    the borrower in connection with certain flipped
    properties if
  • Seller acquired the home less than 180 days
    prior, and
  • New sales price is 10 higher (if seller acquired
    less than 90 days prior) or 20 higher (if 91-180
  • Excludes Qualified Mortgages, open end credit
    plans, reverse mortgage loans, initial
    construction loans, bridge loans, loans secured
    by new manufactured homes transactions secured
    by a mobile home, boat or trailer

ECOA Appraisals Final Rule
  • Equal Credit Opportunity Act (Reg B) Appraisals
  • Final Rule requires notice and copy of appraisals
  • Effective Date Jan. 18, 2014
  • Requires creditors to
  • Notify applicants within 3 business days of
    receiving an application of their right to
    receive a copy of written appraisals valuations
  • Provide applicants a copy of written appraisals
    valuations no later than 3 business days before
  • Prohibits creditors from charging a fee for
    providing a copy of the appraisal or valuation
  • Requirements apply only to appraisals
    valuations made in connection with applications
    for loans secured by a first lien on a dwelling

Escrow Account Final Rule
  • Final Rule on Escrow Accounts for Higher-Priced
    Mortgage Loans (TILA/Reg Z)
  • Final rule issued Jan. 10, 2013 (Board issued
    Proposed Rule Mar. 2, 2011)
  • Effective Date June 1, 2013
  • Implements Dodd-Frank changes that extend the
    length of time escrow accounts must be maintained
    for certain higher-priced mortgage loans
  • Requires accounts to be maintained for at least 5
    years (instead of existing 1 year requirement)
    for closed-end, higher-priced mortgage loans
    secured by a first lien on a consumers principal
  • Account may be cancelled upon termination of the
    underlying debt obligation, including by
    repayment, refinancing, rescission and
  • After 5 years, account may be cancelled at
    consumers request if (a) the unpaid principal
    balance is less than 80 of the original value of
    the property, and (b) the consumer is not
    currently delinquent or in default
  • Continued exemption for open-end loans, loans
    secured by shares in a cooperative, loans to
    finance initial construction of a dwelling,
    temporary bridge loans with a loan term of 12
    months or less reverse mortgages

Upcoming Regulatory Changes
  • Other Rules on the Horizon
  • Integrated Mortgage Disclosures Rule under TILA
  • Final Rule now expected in Sept. 2013
  • Proposed 2 new disclosures
  • Loan Estimate 3 page replacement for GFE/Initial
  • Closing Disclosure 5 page replacement for
    HUD-1/Final TIL
  • Proposed expanded definition of Finance Charge to
    include the 4(c)(7) real estate related fees
    currently exempt
  • HMDA Changes
  • Not effective until CFPB issues final regulation
  • Will require collection of additional data
    including points fees, difference between the
    loan APR benchmark rate for all loans,
    prepayment penalty term, value of any collateral,
    loan term in months, applicants age credit
    score, originators ID number
  • Credit Risk Retention (QRM)
  • Final Rule expected in 2013
  • Requires 5 credit risk retention of all but
    least risky mortgages

Other Hot Regulatory Topics
  • CFPB Exams of Non-Bank Mortgage Companies
  • Recess Appointment
  • Fair Lending
  • FHA
  • Tighter Requirements
  • Higher Premiums
  • More Stingy on Claims
  • More Enforcement Actions, Indemnification Demands
  • Servicing
  • More Servicing Regulations, Oversight
  • Cost of Servicing will Rise
  • Servicing Spreads will Rise
  • Rates will Rise
  • Advertising Marketing Home Warranties
  • RESPA Transferred to the Bureau
  • Still No GSE Solution in Sight

  • What Can You Do?
  • Make Compliance Your Top Priority
  • Company wide, on every level
  • System for employees to report problems to
  • Stay Informed
  • Be ready for upcoming changes
  • Continual Training
  • Significant amount of new regulatory requirements
  • Work with Integrity No Shortcuts
  • Personal responsibility liability
  • No second chances

An Overview and Understanding of The New CFPB
PC1300 19th Street, NW, 5th FloorWashington, DC
20036Phone 202-628-2000
  • Washington, DC Dallas, TX Newport Beach,
Write a Comment
User Comments (0)