Are You Communicating Enough With Your Appraisers? – Part One
Effective October 3rd, property appraisals will generally be subject to a zero tolerance threshold under the Integrated Disclosure Rule (“TRID”). TRID provides that fees paid for a third-party...
View ArticleAre You Communicating Enough With Your Appraisers? – Part Two
On September 1st we began our discussion related to disclosure of the property appraisal fee on the Loan Estimate. Remember that after October 3rd the Integrated Disclosure Rule (“TRID”) provides that...
View ArticleA Smorgasbord of Mortgage Compliance Updates
Last week I had the pleasure of spending time with the more than 200 attendees of the Credit Union National Association’s Regulatory Compliance School in Boston. Given it was my first visit to...
View ArticleA Post-TRID World: Installment One
Well, it’s October 13th and our latest compliance Y2K moment is now in the rearview mirror. The Consumer Financial Protection Bureau’s Integrated Disclosure Rule (“TRID”) took effect on Saturday,...
View ArticleA Post-TRID World: Installment Two
Welcome back to our blog series dedicated to discussing post-implementation issues being experienced by credit unions in the Integrated Disclosure Rule (“TRID”) world. While it’s been eerily quiet on...
View ArticleA Post-TRID World: Installment Three
For installment three of our blog series dedicated to discussing post-implementation issues related to the Integrated Disclosure Rule (“TRID”), I’d like to discuss who is entitled to receive a copy of...
View ArticleA Post-TRID World: Installment Four
Our blog series discussing post-implementation issues related to the Integrated Disclosure Rule rolls on. In today’s installment, I’d like to discuss a few technical questions we’ve been receiving...
View ArticleDeck the Halls with Regulatory Relief: Congress Eliminates Annual Privacy...
On Friday, December 4th President Obama signed into law the Fixing America’s Surface Transportation Act (“FAST”). FAST is a 5-year, $305 billion highway funding package. OK, so what does this have to...
View Article2015: The Year in Review… And a Look Ahead
Regulatory compliance in the area of mortgage loan origination underwent substantial transformation in 2015. And according to the most recent installment of the Unified Agenda of Regulatory Actions,...
View ArticleStaying On Top of SCRA Compliance
I’ve long advocated for the protections afforded by the Servicemembers Civil Relief Act (“SCRA”). I think we can all agree that if there was ever a group that your credit union should bend over...
View ArticleRequest Access to Defense Manpower Database by February 1st
Later this year, the Department of Defense’s revisions to the Military Lending Act (“MLA”) will take effect. As we get closer to the effective date of October 3rd be sure to stay tuned to...
View ArticleAre you making fair lending compliance a top priority in 2016?
A reasonable answer to this question would be “I’m trying.” We’ve survived, to some extent, implementation of the ability to repay rule and the integrated disclosure rule. And now the Consumer...
View ArticleCFPB Issues Guidance on Construction Loans / TRID
Good Tuesday morning from our nation’s capital! I’m happy to be in attendance alongside the nearly 5,000 credit union professionals at this year’s CUNA Governmental Affairs Conference (GAC). GAC is a...
View ArticleLoan Originator Training
Regulation Z requires that loan originators undergo periodic training commensurate with their day to day originator responsibilities. But what training is sufficient to satisfy this requirement? Join...
View ArticleAn Assortment of Mortgage Lending Compliance Updates
There have been a handful of compliance updates relative to mortgage lending over the past couple of weeks. Let’s take a few minutes to discuss them… Small Creditors Small creditors operating in rural...
View ArticleCompliance Education and Training: What You Don’t Know CAN Hurt You
Last week I had the pleasure of speaking to over 250 credit union professionals at CUNA’s Regulatory Compliance School in St. Pete Beach, Florida. The attendance numbers for the introduction school...
View ArticleCFPB Remains Active in the Mortgage Compliance Space
Amendments to the Mortgage Servicing Rules As blogged about here on The Works Blog, in December 2014 the Consumer Financial Protection Bureau (“CFPB”) published a proposed rule recommending many...
View ArticleMilitary Lending Act Implementation: Determining Covered Borrower Status
As previously discussed on The Works Blog both here and here, last summer the Department of Defense (“DOD”) finalized sweeping changes to the Military Lending Act (“MLA”) that take effect this coming...
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