The drop in warehouse commitments mirrored, somewhat, the fall-off in residential originations, which declined almost 19 percent in the third quarter, according to figures compiled by Inside Mortgage Finance.
The CFPB and five other federal financial regulatory agencies issued a supplemental final rule last week that creates exemptions from certain appraisal requirements for a subset of higher-priced, higher-risk mortgage loans. The final rule provides that loans of $25,000 or less and certain “streamlined” refinancings are exempt from the Dodd-Frank Act appraisal requirements, which go into effect on Jan. 18, 2014. In addition, the final rule contains special provisions for manufactured homes, which can present unique issues in...
The Mortgage Bankers Association has put together some guidance, drawn from conversations with CFPB staff, on how to exclude affiliate fees in the points-and-fees calculation for qualified mortgages under the agency’s ability-to-repay rule, which takes effect in just a few weeks. The bureau’s ATR and Home Ownership and Equity Protection Act rules contain a cap or limit on points and fees to qualify as a QM loan and a specific points-and-fees threshold triggering HOEPA coverage. The calculation of points and fees under both of these...
Officials from the CFPB and the Federal Reserve held a webinar earlier this month to help small creditors understand qualified mortgage lending under the bureau’s ability-to-repay rule. To begin with, there are two special categories of QMs for small lenders, portfolio QMs and balloon QMs. Also note that the ATR rule provides additional flexibility to small lenders in that the safe harbor has been expanded to 3.5 percent over the average prime offer rate. The first step to determine eligibility – of both the lender...
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