SAFE! In addition to being in the top tier of regulations whose framers worked extra hard to come up with a pronounceable and relevant acronym (right up there with E-SIGN and the USA PATRIOT Act), the Secure and Fair Enforcement for Mortgage Licensing Act, a.k.a. SAFE Act, is also in the top tier [...]
Recently, our firm participated in an NCUA-sponsored workshop devoted to the Bank Secrecy Act. This event was immensely popular, attracting some 2,000 attendees. Of course, with that many in attendance, it was impossible to get to all the questions that were asked. Hence, we've decided to group the most popular questions into five representative questions [...]
—No, they really are this time. The CFPB has released an updated small entity compliance guide on the TILA-RESPA Integrated Disclosure rule. As you may remember the Dodd-Frank Wall Street Reform and Consumer Protection Act directed the newly created CFPB to integrate the mortgage loan disclosures under TILA (Regulation Z) and RESPA (Regulation X) back in [...]
Asking which is the most common compliance question is like asking which is the most popular ice cream flavor—kind of expected (it’s vanilla according to the International Dairy Foods Association). But rather than deal with the obvious, vanilla question of “How do I ensure a satisfactory rating on my next compliance examination?” I’ve categorized questions [...]
There’s nothing more frustrating than believing, nay, knowing that you are an exempt from a requirement only to find out after reading the commentary that the regulation actually denotes the opposite. The feeling could be compared to that of walking up the stairs, expecting one more stair at the top, when suddenly, your foot falls [...]
The CFPB has released the examination procedures for the new Remittance Transfer Rule, which is an amendment of Regulation E or Electronic Funds Transfer Act (EFTA). The final rule went into effect on Monday October 28th. 2013. The CFPB examination procedures contain a breakdown of audit procedures, a summary of the regulation itself and a [...]
The second in a series of posts on the new mortgage servicing rules. The Error Resolution and Information Requests Rule establishes error-resolution procedural requirements for responding to (1) Notices of Error and (2) Information requests. Basically, there was a high number of complaints during the mortgage foreclosure crisis about the lack of communication from lenders. [...]
The first in a series of posts on the new mortgage servicing rules. The CFPB has issued the Final Rule for Mortgage Servicing, which will be effective on January 10, 2014. Among the numerous changes to mortgage servicing, there are several significant amendments to Regulation X (RESPA) and Regulation Z (TILA). On the compliance tsunami [...]
Just for fun, let’s break down the new mortgage servicing rules that are due to be implemented next January. In this series of articles, we are going to look at the new amendments in the Dodd-Frank Legislation that are collectively referred to as the Mortgage Servicing Rules. There are roughly eight amendments to Regulation X [...]
The annual MLO (Mortgage Lending Originators) registration renewal period is coming! As you will all remember, the Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act) created the NMLS Federal Registry where all mortgage lending originators (MLOs) must be registered before working. The annual renewal period begins on November 1, 2013. Every MLO at your [...]
