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April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
Andy Zavoina

May 15
Managing Electronic Information - From A to Zettabyte
Fred Menge



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#1282265 - 11/06/09 08:44 AM Avoiding the HPML Threshold
Cale_N_Oats Offline
Platinum Poster

Registered: 08/14/08
Posts: 738
Loc: Southern Illinois
I recently got back from a Compliance seminar and one thing that was discussed was higher priced mortgage loans. One suggestion for manuvering around the HPML threshold would be to make a first mortgage for a low amount at a lower rate and then make a second mortgage for the larger amount. This would give you a little more wiggle room since with the second lien you would be looking at a 3.5% threshold rather than the entire amount on a first lien at a 1.5% threshold. Does anyone know if the regulation prohibits this or has their been and commentary on the matter?
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Lending Compliance
#1282278 - 11/06/09 08:56 AM Re: Avoiding the HPML Threshold [Re: Cale_N_Oats]
Sinatra Fan Online
Power Poster

Registered: 07/19/02
Posts: 5291
Loc: New Jersey
As long as neither loan is an open-end loan, I think you may be OK. 12 CFR 226.35(b)(4) specificially prohibits structuring a home loan as an open-end loan to evade the requirements of the HPML section.

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#1282708 - 11/06/09 12:54 PM Re: Avoiding the HPML Threshold [Re: Sinatra Fan]
Cale_N_Oats Offline
Platinum Poster

Registered: 08/14/08
Posts: 738
Loc: Southern Illinois
Thats what i thought too. Besides totally spitting in the face of the regulation i couldn't find anything wrong with it either.
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#1282716 - 11/06/09 01:03 PM Re: Avoiding the HPML Threshold [Re: Cale_N_Oats]
Truffle Royale Offline

10K Club

Registered: 07/09/03
Posts: 13764
And I STILL don't get the big deal with HPML that it has to be manuvered around. Seriously, what are people trying to avoid and why? I'd rather make a borrower escrow than have to duck and weave around my examiners.

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#1282800 - 11/06/09 02:02 PM Re: Avoiding the HPML Threshold [Re: Truffle Royale]
Cale_N_Oats Offline
Platinum Poster

Registered: 08/14/08
Posts: 738
Loc: Southern Illinois
haha, i hear you Truffle, this was just something brought up by some old school banker that will eventually come back to bite him. I personally don't find anything wrong with escrowing, it's not hard most of it is automated.
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