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Inside the CFPB
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TRID Ushering in New Tech Paradigm, Pros Say

July 3, 2015
The pending implementation of the integrated disclosures rule is driving a sea change in at least two critical areas: technology innovation and regulatory expectation. Competency with the former will facilitate the fulfillment of the Consumer Financial Protection Bureau’s so-called TRID rule, according to speakers at the American Bankers Association’s recent regulatory compliance conference in Washington, DC. The rule, now scheduled to take effect Oct. 3, requires new consumer disclosures under the Truth in Lending Act and…
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GSE Loans Protected by New Super-Priority Lien Ruling in Nevada

July 2, 2015
The GSEs benefited from the Consumer Financial Protection Bureau’s free pass on the debt-to-income ratio requirements of the qualified-mortgage rule, resulting in a $132.9 billion increase in business.A new Inside Mortgage Finance analysis of mortgage-backed securities data illustrates that from the beginning of 2014 through the end of the first quarter of 2015, approximately 16.3 percent of the loans securitized by Fannie Mae and Freddie Mac had DTI ratios exceeding 43 percent. In the non-agency world, a qualified mortgage has to have a DTI ratio of 43 percent or less. While the government-insured market has its own QM rules that effectively ignore DTI, a loan eligible for sale to the GSEs is considered...
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Higher Interest Rates Could Cause Performance Problems For Commercial MBS

July 2, 2015
An increase in short-term interest rates will have an outsized impact on commercial MBS among structured finance assets, according to Moody’s Investors Service. In a report released last week, the rating service said higher interest rates will be credit negative for existing deal performance and new issuance for commercial MBS and largely neutral for residential MBS and most ABS sectors. As interest rates rise, Moody’s said term default risk on loans backing new issue commercial MBS will increase because the loans’ debt service coverage ratios will be lower than the DSCRs at the time of origination of loans in outstanding deals. “Rates on loans backing new conduit deals will increase, thereby reducing DSCR in relation to a given property’s cash flow,” the rating service said. “New conduit deals are typically backed by loan pools that were originated no more than ...
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So, Is the FHA Still Sick or Not?

July 1, 2015
George Brooks
The report from Potomac Partners bears the good news about FHA...
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SCOTUS Decision on Disparate Impact Could Embolden the CFPB

July 1, 2015
Thomas Ressler
FBR Capital Markets analysts said the ruling allows the CFPB and the Department of Justice to retain their use of disparate impact under the Equal Credit Opportunity Act...
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OCC: Banks Face $131 Billion of Resetting HELOCs

July 1, 2015
Brandon Ivey
For most HELOCs, the OCC said the end-of-draw period means that monthly payments change from interest-only to amortizing...
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Big Pay Raises for Fannie and Freddie CEOs; How Does $4 Million a Year Sound?

July 1, 2015
Paul Muolo
A few years back, then FHFA Director Ed DeMarco cut the compensation of the CEOs as a response to lawmaker concerns.
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Short Takes: GSEs Hike LPMI Capital Requirements / Is LPMI Really Riskier? / The Trouble with Mortgage Co-ops and Free AU / Applications Wane / Hiring at NMI

July 1, 2015
John Bancroft, Paul Muolo, and Sherry Muolo
The Consumer Financial Protection Bureau also is reviewing LPMI, but from a different angle: RESPA and the "discounting" of such policies…
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Lenders Face Higher Standard of Conduct in Wake of SCOTUS Ruling on Disparate Impact, Attorneys Say

July 1, 2015
Late last week, the Supreme Court of the United States delivered some long-sought clarity on the legitimacy of disparate-impact claims brought under the Fair Housing Act in the case of Texas Department of Housing and Community Affairs v. The Inclusive Communities Project, Inc. The highest court in the land validated the position of various lower courts, regulatory agencies and administrations over the last four decades that disparate impact is ...
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Servicers Large and Small Oppose Plan by States To Impose Capital Requirements on Nonbanks

July 1, 2015
Capital requirements and standards proposed by state regulators for nonbank servicers appear to be unnecessary, according to trade groups representing servicers. State regulators issued the proposal in March, seeking to ensure that nonbanks conduct their servicing operations in a safe and sound manner and have strong consumer protections in place. “It is not clear that nonbank mortgage servicers require a prudential regulatory regime,” a group of 37 state ...
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