PPDocs System Training CFPB changes effective January 2014

Similar documents
Section Ability to Repay (ATR) (c)(1) and Qualified Mortgage (QM) (e), (f)

THIS IS NOT LEGAL ADVICE

Enhancing HOEPA: The CFPB s Changes to Regulations Z & X

Qualified Mortgages and Qualified Residential Mortgages under the Dodd-Frank Act

Mortgage Lending Compliance Issues Session 1. Higher Priced and High-Cost Mortgages

TIPS BULLETIN #13-17

Dodd-Frank Rules Frequently Asked Questions Wholesale

Fully Amortizing Payment A periodic payment of principal and interest that will fully repay the loan amount over the loan term.

11 th Annual Eastern Secondary Market Conference. February 5-7, 2014 The Hyatt Regency Orlando

PPDocs, Inc. Compliance Certificate

Dodd-Frank Implementation Checklist

Understanding CFPB Rules CONSUMER FINANCIAL PROTECTION BUREAU

Notice Regarding Updated Regulations and Summary of Recent CFPB Mortgage Rules

New Lending Opportunities in the Changed Mortgage Market: Dodd-Frank Act Mortgage Regulations

CFPB s Final Mortgage Regulations: Ability-to-Repay and Qualified Mortgage Rules March 6, E. Andrew Keeney, Esq. Kaufman & Canoles, P.C.

ABILITY TO REPAY AND QUALIFIED MORTGAGE UNDERWRITING REFERENCE

CFPB FINAL RULES SUN WEST IMPLEMENTATION GUIDE

ABILITY TO REPAY AND QUALIFIED MORTGAGE UNDERWRITING REFERENCE

TIB 2016 Annual Conference Small Creditor and Rural or Underserved Updates By: Venessa Snell

Ability-to-Repay and Qualified Mortgage Rule (ATR/QM Rule)- Effective 1/10/14

Ability To Repay (ATR) Creditors must determine that borrowers have a reasonable ability to repay a loan based on consideration and verification of

Small Creditor Revisions ATR & QM Requirements

Compliance Update - ACUIA. Presented by:

2013 Home Ownership and Equity Protection Act (HOEPA) Rule Guide

ATR/QM Points & Fees Broker FAQ s

Ability to Repay / Qualified Mortgages Frequently Asked Questions January 15, 2014

How to Start Planning for the CFPB Mortgage Rules. May 2, 2013

Webinar Wednesday, March 26, :00 3:15 pm ET For Audio Dial (800)

ATR/QM FAQ DISCLAIMER:

Regulation Z Michelle Nuckols, CRCM. financial services

With so much change, be sure to stay up to date!

Mortgage Bankers and Brokers Association of New Hampshire

Qualified Mortgages-Update. Wilkes B. Hardin, MBA, CFE VP, Lending Compliance WSECU

RULES AND AMENDMENTS TO REGULATION Z

Mortgage Reform Under the Dodd-Frank Act

What s New in Mortgage Lending Compliance?

Ability to Repay and Qualified Mortgage Rules

Re: Amendments to the 2013 Escrows Final Rule under the Truth in Lending Act. Regulation Z [Docket No. CFPB ]

Recent CFPB Mortgage Rules to Absorb and Implement

Testing for Qualified Mortgage Status

Reasons for Change. Are You Ready for the Regulation Z & RESPA Changes. Past, Present & Future Changes

ABILITY-TO-REPAY: REGULATING OR UNDERWRITING? PART I. Author: Jonathan Foxx

Jefferson County Housing Market Update

2013: The Year Ahead for Mortgage Lending. Presenters: Suzanne Garwood, Esq., Venable LLP Ken Markison, Esq., Mortgage Bankers Association

Bodman PLC Detroit, Troy, Ann Arbor, Cheboygan, MI Dallas, TX Affiliate Office Presented By: Howard A. Lax.

Mortgage Bankers Association Regulatory Update

MORTGAGE REFORM UNDER THE DODD FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT

Qualified Mortgage (QM) Initiative December 15 th, 2013 Updated January 5 th, 2013 (Update to Page 6 Broker Compensation Cap)

x Trusts Other: Other: x RHS x Lot Loan x Borrower Interim x HELOC

Consumer Regulatory Changes

Federal and State Law Updates

Advertising, Consumer protection, Mortgages, Reporting and recordkeeping

LAW: Maine Consumer Credit Code - Truth-in-Lending; ME Predatory Lending Act effective 1/1/08 (ME Rev Stat Ann Title 9-A, Section 8-506(1)(H))

Any person, who for direct or indirect compensation, assists a consumer in obtaining or applying to obtain a residential mortgage loan; or

Board of Governors of the Federal Reserve System; Truth in Lending

The Quality Control Process and Its Impact on Compliance Goals

Summary of Reportable HMDA Data Regulatory Reference Chart a

Quarterly Report Mid-South Regulatory Compliance Group

Ability-to-Repay Rule

Compliance Essentials/CMCP: Overview of Consumer Protection Compliance The Dodd Frank Rules Sunday, September 17, 2017

Re: CFPB Request for Information regarding the Ability-to-Repay/Qualified Mortgage Rule Assessment

1) The credit union's assets total more than $44 million as of December 31, 2017,

2013 CFPB. Mortgage Regulation U P D AT E

2/4/2014. Consumer Financial Protection Bureau Update A New Era of Regulation Begins. A Quick Overview of the CFPB. CFPB Overview (cont.

VA IRRRL PROGRAM MATRIX

MORTGAGE REFORM AND ANTI-PREDATORY LENDING ACT of 2009

Joe Gendron, Director of Government Relations 5555 Bankers Avenue, Baton Rouge, LA (225) ,

HMDA Regulations and New 1003 Application - Part 2

TILA Mortgage Coverage Categories Closed-End Mortgages Secured by Dwelling (DF)

FNMA Home Affordable Refinance Program (HARP) Transaction Type Number of Units Fixed Rate Max LTV/CLTV

Closing Disclosure $ NO $ $ Loan Terms. Projected Payments. Costs at Closing

TESTIMONY OF MR. JERRY REED CHIEF LENDING OFFICER ALASKA USA FEDERAL CREDIT UNION ON BEHALF OF THE CREDIT UNION NATIONAL ASSOCIATION

Loan Originator Compensation Guide

Mortgage Regulation Update

Closing Disclosure $ NO $ $ Loan Terms. Projected Payments. Costs at Closing

Compliance Update. NCSHA 2018 HFA Institute Washington, D.C. January 11, 2018

JUMBO A PROGRAM GUIDE

Section 1.35 Compliance Overview

Testimony of. Kenneth E. Bentsen Jr., Executive Vice President, Public Policy and Advocacy. Securities Industry and Financial Markets Association

Non-QM. Qualified Mortgages General QMs. GSE QMs. Agency QMs. Points & Fees 5%

Interagency Consumer Laws and Regulations

TO: Freddie Mac Sellers and Servicers November 15,

Version 5/15/14 REV (08/10/16) Posted 08/10/16 Page 7-i

Facing Today s Real Estate Regulations

Q: Any discussion regarding tolerance violations with all the new additional fields?

Truth in Lending / RESPA Regulatory Changes

2018 HMDA Implementation. Presented By: Karen Ruckle, Director of Compliance Bank of the Ozarks

ditech BUSINESS LENDING CONFORMING FIXED RATE PRODUCT (FANNIE MAE ELIGIBLE)

Summary of CBA s Comments

Covered loans or applications if the property is

REQUEST FOR GUIDANCE ON THE CONSUMER FINANCIAL PROTECTION BUREAU S MORTGAGE ORIGINATION REGULATIONS. Updated September 26, 2013

Quarterly Report Mid-South Regulatory Compliance Group

ditech BUSINESS LENDING JUMBO PRODUCTS

Fannie Mae has specific requirements for multiple financed properties:

8:1 CONFORMING FIXED RATE

(TC) TRADITIONAL PROGRAM MATRIX CONFORMING & HIGH BALANCE

PREMIER JUMBO PROGRAM GUIDE

MORTGAGE LENDING PRINCIPLES & PRACTICES, 8TH ED. 2ND PRINTING

Operational Impacts of the Economic Growth, Regulatory Relief, & Consumer Protection Act (S.2155)

Tennessee STATE HIGH COST/PREDATORY LENDING REGULATIONS Last Updated: 2/28/18_ By: BH Coded: _3/5/2018 By: _ZB Reviewed: By:

Transcription:

PPDocs System Training CFPB changes effective January 2014

Please direct all questions to: CFPB@ppdocs.com

What you should be doing today: What type of QM are you going to be doing? *Are you going to be doing Higher Priced QM Identify your affiliates

Affiliate: Any company that controls, is controlled by, or is under common control with another company. Control means a minimum of 25% interest

What you should be doing today: What type of QM are you going to be doing? *Are you going to be doing Higher Priced QM Identify your affiliates Run test loans in the PPDocs system Determine if you qualify for a small creditor QM

Small Creditors: Lenders, including their affiliates, having no more that $2 billion in assets and originating no more than 500 first lien mortgages a year.

What you should be doing today: What type of QM are you going to be doing? *Are you going to be doing Higher Priced QM Identify your affiliates Run test loans in the PPDocs system Determine if you qualify for a small creditor QM Determine if you qualify as a lender serving rural and underserved areas

Rural Creditors: Creditor must extend over 50% of its loans in predominantly rural or underserved areas.

Section 32 Changes Now includes any closed-end consumer credit transaction secured by a principal dwelling. Purchase Money Transactions HELOC Bridge Loans to obtain principal dwelling Home Improvement (Interest or P&I) Temporary Closed-end Home Equity Loans Refinancing of closed-end Purchase Money or home equity loan HOEPA definitions do not include: Initial Construction Loans Reverse Mortgages Originated or directly financed by Housing Financing Agency (HFA) Originated or directly financed USDA Rural Development Section 502 Direct Loan Program Non-owner occupied refinances and second home mortgages

There are no substitutions for the Rules themselves! This webinar is meant to highlight the changes to our website and order forms for the upcoming changes.

Qualified Mortgages are broken down into 5 main classifications: General QM: Has no toxic loan features Must pass points and fees test Maximum debt to income ratio of less than or equal to 43%

Qualified Mortgages are broken down into 5 main classifications: Temporary QM (GSE Eligible): Subject to the same rule as General QM Also subject to the individual GSE s underwriting requirements

Qualified Mortgages are broken down into 5 main classifications: Balloon QM: Subject to the same rules as General QM For creditors who pass the rural and underserved test Balloon loans under this classification are restricted by o Calculating payments based on a maximum of 30 year amortization o Interest rate cannot increase over the term (fixed rate) o Minimum loan term of 5 years.

Qualified Mortgages are broken down into 5 main classifications: Small Creditor QM: Temporary classification to allow smaller credit unions and community banks a 2 year transition period for loans held in portfolio Increases HPML threshold to allow these loans to maintain safe harbor.

Qualified Mortgages are broken down into 5 main classifications: Small Creditor Balloon Payment QM: Must be held in portfolio 2 year transition period The loan must have a fixed interest rate and periodic payments (other than the balloon payment) that would fully amortize the loan over 30 years or less. The loan must have a term of five years or longer. Must consider consumer s debt-to-income ratio or residual income Sunsets January 10, 2016

FNMA defines bona fide discount points as: Points paid that result in a bona fide reduction of the note rate, provided the interest rate reduction is reasonably consistent with established industry norms and practices. A point will be presumed to be bona fide if it reduces the note rate by a minimum of 25 basis points, assuming all other loan terms remain the same.

What to do going forward: Modify your templates Register for webinars Test loans

Thank you for your business!