Plain and Simple: if you weren’t already aware, the CFPB is looking to combine TIL and RESPA disclosures into one document. Home loan disclosures are being redesigned, again! READ MORE
Interesting timing for such a major change isn’t it. A necessary evil, but still interesting timing. These updates are moving forward regardless of the fact that no real clarity has been offered on the future of the housing finance mechanism (GSEs). And even more closely related to the disclosure updates themselves, the industry is attempting to reform its entire compensation model right now. How can we expect lenders to interpret and implement new originator compensation models without knowing how the new consumer disclosure package will look? How can we expect lenders to keep the mortgage market competitive if we don’t have a clear indication of how loans will be securitized. I can go on and on here…HOW ABOUT THE RISK RETENTION REGS? WHAT IS CONSIDERED A QUALIFIED LOAN?
I don’t have a problem with the abundance of reforms that have been outlined for the mortgage industry, but maybe we should approach one major reform at a time to ensure we get the job done right. Compliance folks can only be spread out so far before their oversight wears thin.
The final compensation rules are effective April 1,
Posted via email from Title Insurance To prohibit Fannie Mae, Freddie Mac, and Ginnie Mae from owning or guaranteeing any mortgage that is assigned to the Mortgage Electronic Registration Systems or for which MERS is the mortgagee of record. –> H.R. 6460–111th Congress: To prohibit Fannie Mae, Freddie Mac, and Ginnie Mae from owning or guaranteeing any mortgage that…. (2010). In GovTrack.us (database of federal legislation). Retrieved December 8, 2010, from http://www.govtrack.us/congress/bill.xpd?bill=h111-6460 “H.R. 6460–111th Congress: To prohibit Fannie Mae, Freddie Mac, and Ginnie Mae from owning or guaranteeing any mortgage that….” GovTrack.us (database of federal legislation). 2010. December 8, 2010 The interesting part of this bill for us is section 3: (a) Study- The Secretary of Housing and Urban Development, in consultation with the Comptroller General of the United States, shall conduct a study to analyze and determine– (1) the impacts of the lack of electronic records and uniform standards found in local land title recordation systems currently used in the various States; (2) any progress States have made in developing electronic land title recordation systems for their localities that contain uniform standards, and any findings and conclusions and best practices resulting from such development; (3) the current oversight role of the Federal Government in the transfer and recordation of land titles; (4) opportunities, and the feasibility of such opportunities, that may be present to leverage progress made by some States and localities to create an electronic land title recordation system, including through– (A) a system that would maintain all previous records of the land-property without invalidating, interfering with, or preempting State real property law governing the transfer and perfection of land title; and (B) further actions by the States or by the Federal Government, or coordinated actions of both; and (5) the feasibility of creating a Federal land title recordation system for property transfers that would maintain all previous records of the land-property without invalidating, interfering with, or preempting State real property law governing the transfer and perfection of land title. (b) Report- Not later than the expiration of the 12-month period beginning on the date of the enactment of this Act, the Secretary of Housing and Urban Development, in consultation with the Comptroller General of the United States, shall submit to the Congress a report on the results and findings of the study conducted under this section. If the Bill gets out of committee, it will be one to watch. Posted via email from Title Insurance We are still handling OTI the same way we did it when the new RESPA rules went into effect in January because I was waiting for more clarification – or something – from HUD. This is what we do (which I believe follows instructions in the FAQ): Our Software vendor seems to be making changes to comply with the RESPA Roundup which says: 1) Is the “consumer” in this case our borrower or does it mean any consumer (seller) associated with the loan? We usually pay for the flood determination rather than passing the fee to the consumer. We handle it basically the same way we do the OTI. What I want to ask is Why? Why? Why? But I know it’s pointless so I won’t. Taken from the Banker Online Blog. Posted via email from Title Insurance
Continuing Ed for Title Agents
H.R. 6460: To prohibit Fannie Mae, Freddie Mac, and Ginnie Mae from owning or guaranteeing any mortgage that… (GovTrack.us)
Overview
Full Text
Introduced
Nov 30, 2010
Referred to Committee
View Committee Assignments
Reported by Committee
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House Vote
…
Senate Vote
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Signed by President
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Nov 30, 2010: Referred to the House Committee on Financial Services.
{{cite web |url=http://www.govtrack.us/congress/bill.xpd?bill=h111-6460 |title=H.R. 6460 |accessdate=December 8, 2010 |author=111th Congress (2010) |date=Nov 30, 2010 |work=Legislation |publisher=GovTrack.us |quote=To prohibit Fannie Mae, Freddie Mac, and Ginnie Mae from owning or guaranteeing any mortgage that... }}
SEC. 3. HUD STUDY.
Continuing Ed for Title Agents
RESPA FAQ vs. RESPA Roundup I’m VERY confused – Bankers Online
A) Always put OTI on the GFE for home purchase loans.
B) Put OTI in the borrower’s column on the HUD-1.
C) Show a credit for OTI in the 200 Series and a charge to the seller in the 500 series.
D) The comparison chart contains amounts in the GFE and HUD column for OTI.
“If the consumer did not purchase a service that was listed on the GFE (usually owner’s title) there should be nothing entered in that line on Page 2 of the HUD-1 and the estimate of the charge should not appear on the comparison chart on Page 3 of the HUD-1.”
2) Is HUD saying to show the OTI in the Seller’s column of the HUD-1?
3) Does HUD still expect us to put the OTI on the GFE for a purchase?
•Does this also fall off of the comparison chart now?
Continuing Ed for Title Agents
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