Tag: QM

CFPB- Truth in Lending (Reg Z) – Annual Threshold Adjustments for HOEPA and Qualified Mortgages

Written By: Tammy Butler, Master CMB Annual Thresholds for Qualified Mortgages have been issued by the CFPB. Rule Synopsis: The Bureau is required to calculate annually the dollar amounts for several provisions in Regulation Z; this final rule reviews the dollar amounts for provisions implementing TILA and amendments to TILA, including the Home Ownership and […]

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Universal – Loan Quality Types: With the expansion of loan products, what are the differences between Non-QM and Sub-Prime loans?

Answer: There is a lot of discussion on Non-QM business as lenders have compressed margins and they are looking for loans that allow them to deviate slightly from secondary marketing constrictions and not concern themselves with the points and fees test.  Of course, doing non-QM means that there is more risk and more risk equals […]

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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; […]

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Compliance – Lender Credits – If the borrower locks the rate, and then decides to lower the loan amount, can we lower the lender credit to the borrower?

Answer: The quick answer probably won’t make you happy. It is my opinion, based on information from the CFPB’s Small Entity Compliance Guide, that the lender credit cannot be changed even if there is a material change to the loan amount. Reference:  Question 7.13 on page 59 of the small entity compliance guide from the […]

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Consumer Financial Protection Bureau Releases List of Counties for 2018 that Qualify for Rural or Underserved Counties – Dated March 2018

By: Lloyd Rutherford, Staff Writer The CFPB removes some of the regulatory burdens for small institutions so that access to credit is available to rural and underserved areas.  This article identifies those areas and gives you some tips about how to create that niche market. Rule Synopsis: Consumer Financial Protection Bureau updates counties for rural […]

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