Points and Fees

Compliance – QM Test Failing Over MI: We have a high-balance conventional loan failing QM due to borrower-paid single premium. Any ideas for how to cure that?

Answer: You are running into this issue because borrower-paid single MI is included in the points and fees cap.  Borrower-paid monthly MI or Lender-paid MI is not included in the points and fees cap. If the borrower is paying the MI outside of monthly, then we can only suggest switching over to a Split Premium type product [...]

2018-11-25T20:07:16-05:00November 25th, 2018|

CFPB – Truth in Lending Annual Threshold Adjustments – Entered in Federal Register August 27, 2018 – Effective January 1, 2019

Written By: Tammy Butler, Master CMB Each year, the CFPB is mandated to adjust tolerance thresholds under HOEPA and QM.  Be sure to read this article to understand what is changing and when it goes into effect. Rule Synopsis: The Bureau is required to calculate annually the dollar amounts for several provisions in Regulation Z; [...]

2018-09-10T11:25:16-05:00September 9th, 2018|