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CFPB Issues Proposal to Address the TRID ‘Black Hole’

July 19, 2017
Thomas Ressler
Currently, lenders are permitted, under certain limited circumstances, to use revised estimates…
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Fannie/Freddie Single-Family MBS Business Slumped in 2Q17; Bank and Thrift Business Weak

July 18, 2017
John Bancroft
Wells Fargo saw an 18.6 percent drop in its GSE business during the April-June cycle, but the three other megabanks had much bigger declines…
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Flagstar Bancorp to Issue its First Post-Crisis Jumbo MBS

July 18, 2017
Brandon Ivey
All of the mortgages Clayton reviewed for the MBS are safe harbor qualified mortgages.
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Residential Production at BofA Rises 16 Percent; MSR Balances Continue to Fall

July 18, 2017
Paul Muolo
Compared to the same period a year ago, servicing balances have fallen by 19.5 percent.
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Walter’s Warehouse Lenders Show Patience – but for How Long?

July 18, 2017
Paul Muolo
In late May, Walter disclosed in an SEC filing that some of its previously issued financial statements could not be relied upon because of what it called an “accounting error.”
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CFPB Suffers Another RESPA Blow; A Victory for Affiliated Business Arrangements?

July 18, 2017
Thomas Ressler
It’s unclear whether the CFPB will appeal the decision. Bureau officials declined to comment.
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Short Takes: EverBank CEO Now the Head of LenderLive / Strong Volumes at Skyline / Refi Shops Hurting / Walter Files Layoff Notice on Irving Office / loanDepot Snatches Top LO from Guaranteed Rate

July 18, 2017
Paul Muolo
Walter Investment filed a WARN notice with the Texas Workforce Commission, saying it will close its Irving, TX, office and cut 437 workers...
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Most Mortgage Gripes Plunge – Except for Loan Servicing

July 18, 2017
Thomas Ressler
Specialty servicers Ocwen and Ditech Financial ranked third and fifth, respectively, in mortgage complaints during the first six months of 2017, according to Inside the CFPB.
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CFPB Codifies Final Changes to TRID, Permits Sharing of the CD

July 17, 2017
The CFPB recently published long-awaited updates to its “Know Before You Owe” integrated disclosure mortgage rule, finalizing, among other things, amendments on finance charge disclosures, disclosures tied to housing assistance that a borrower receives, and when information can be shared with third parties, including real estate agents. The KBYO rule took effect in early October 2015 as part of an effort to simplify disclosures under two laws: the Truth in Lending Act and the Real Estate Settlement Procedures Act. The lending industry commonly refers to the combined disclosures as TRID, short for TILA/RESPA Integrated Disclosure rule. In a statement on the amendments, the CFPB noted that TRID “changed the total of payments calculation so that it did not make specific...
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Bureau Issues Proposed Rule to Address TRID’s ‘Black Hole’

July 17, 2017
In addition to the so-called TRID 2.0 final rule, the CFPB recently issued a notice of proposed rulemaking related to what’s known in the mortgage industry as TRID’s “black hole,” which refers to situations in which a lender is not permitted to use a closing disclosure to reset fee tolerances. More specifically, the proposal addresses when a creditor may use a Closing Disclosure (CD), instead of a Loan Estimate (LE), to determine if an estimated closing cost was disclosed in good faith and within tolerance. Currently, lenders are permitted, under certain limited circumstances, to use revised estimates, instead of the estimate originally disclosed to the borrower, to compare to the charges actually paid by or imposed on the borrower in...
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