Investors in non-agency U.S. residential mortgage-backed securities are unlikely to face much in the way of risk stemming from lender non-compliance with the new requirements of the CFPB’s integrated disclosure rule known as TRID, according to analysts at Fitch Ratings. “Although the frequency of non-compliance issues will likely be elevated initially as lenders implement the new changes, those non-compliance issues are not likely to translate into higher risk for bondholders,” the analysts said in a recent report. Their initial due diligence sampling of prime jumbo mortgages in the secondary market has revealed a high level of compliance issues thus far. However, most of them appear to be good-faith errors. The ratings service is continuing its discussions with market participants on ...
Credit union representatives are urging the CFPB to address the increased regulatory burden associated with complying with the bureau’s new Home Mortgage Disclosure Act regulation, as well as related privacy issues the new rule raises. “The final rule added a significant number of new data points to the reporting requirements established in Regulation C, while modifying almost all the existing data points,” said Alexander Monterrubio, regulatory affairs counsel for the National Association of Federal Credit Unions, in a recent comment letter to the CFPB. While some of the data points were specifically mandated by the Dodd-Frank Act, many of them were added at the bureau’s discretion, and that will prove to be problematic. “These discretionary data points have swelled the ...
In another sign that the mortgage market is continuing to heal – at least from the borrower perspective – consumer complaints to the CFPB about their mortgages continued to drop, falling broadly and by double digits in every category tracked by Inside the CFPB during the fourth quarter. Leading the way during 4Q15 was a 45.1 percent plunge in consumers disputing a company’s response to an original complaint, our analysis of information from the consumer complaint…
On the three-year anniversary of the adoption of the CFPB’s final loan originator compensation rule, the Community Home Lenders Association wrote the bureau, renewing its call for “ending the exemption bank loan originators enjoy from passing a mortgage competency test.” The Jan. 20, 2013, LO comp rule implemented Section 1402(b)(1)(A) of the Dodd-Frank Act, which requires that all mortgage loan originators be “qualified.” In the final rule, the CFPB elected not to impose a Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act) test requirement on bank loan originators or impose other related SAFE Act requirements that are imposed on non-bank LOs. Subsequently, the CHLA has called for higher bank loan originator qualifications standards, including a mandatory universal requirement ...
Here are the Top 10 TRID Deficiencies, According to One Lender. The folks at Stearns Correspondent Lending recently published a list of the top 10 compliance deficiencies associated with the CFPB’s integrated disclosure rule, as follows: 1.The Closing Disclosure was not provided to the borrower within three business days of the closing date. 2. Various unspecified issues with the Loan Estimate.3. The Loan Estimate was not disclosed to the borrower within three business days of the application date. 4. Borrower(s) did not receive the Loan Estimate within four business days of the closing date. 5. The lender failed to provide a valid change of circumstance for all subsequent Loan Estimates in the file. 6. The lender failed to ...
Credit Plus Offers Reps-and-Warrants Coverage to Help Lenders Cope with CFPB, OCC Expectations. Credit Plus, a Salisbury, MD-based third-party verifications specialist for mortgage professionals, has come out with representations-and warranties-insurance coverage for all of its services, responding to the CFPB’s and the Office of the Comptroller of the Currency’s expectation that lenders are now ultimately responsible for practicing effective third-party risk management. The insurance coverage allows customers to better defend their companies against the negative financial consequences of a possible loan default and the resulting repurchase requests, the company said. “While we are confident in the quality of our verification services, we are also a strong proponent of best practices,” said Greg Holmes, national director of sales and marketing at ...
But all is not rosy. At JPM, mortgage servicing balances continue to decline and the bank’s executives expect production margins will compress as origination volumes diminish…