The CFPB, HUD and the Department of Justice have all gone on record asserting that disparate impact claims are viable under the Fair Housing Act and the Equal Credit Opportunity Act.
Currently, FHA requires a waiting period of two years in bankruptcy cases and three years after a foreclosure or short sale before a borrower can apply for an FHA loan.
As expected, we dont believe any mortgages have been sold out of trusts to the city of Richmond, said Tom Deutsch, executive director of the American Securitization Forum.
Roughly, 60 percent of real estate loans made by credit unions are sold to Fannie Mae and Freddie Mac, compared to only 44 percent for all financial institutions.
Fannie Mae and Freddie Mac, at the direction of the Federal Housing Finance Agency, are developing a standardized dataset to support the Consumer Financial Protection Bureaus yet-to-be finalized consolidated closure disclosure forms, the GSEs recently announced. The GSEs new Uniform Closing Dataset is a component of the FHFA-mandated Uniform Mortgage Data Program, which is designed to standardize the way loan data is defined, captured and delivered. The UMDP is a multifaceted, ongoing program in which the GSEs develop and implement mortgage data standards for the single-family loans we purchase and/or securitize, Freddie said. Capturing consistent and accurate data is essential to our ability to effectively assess risk on the mortgages we purchase and will create efficiencies for all industry participants. In conjunction with the uniform appraisal data standards, Freddie said it has worked with Fannie on a joint appraisal data delivery portal, the Uniform Collateral Data Portal, for the electronic capture of appraisal data.