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#1179118 - 05/08/09 03:08 PM
New Reg Z Final Rule - Just Published
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Platinum Poster
Joined: Oct 2005
Posts: 667
Sioux Falls, SD
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#1179129 - 05/08/09 03:12 PM
Re: New Reg Z Final Rule - Just Published
Jerod Moyer
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Power Poster
Joined: Nov 2001
Posts: 7,985
FINALLY ABOVE the gnat line
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Thanks! How did you get that so fast! I'm on the distribution list but haven't received it yet.
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#1179148 - 05/08/09 03:21 PM
Re: New Reg Z Final Rule - Just Published
waldensouth
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Power Poster
Joined: Nov 2000
Posts: 2,701
PA
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So much for thinking (and hoping) the mandatory compliance date might be extended beyond 7/30/09.
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#1179169 - 05/08/09 03:35 PM
Re: New Reg Z Final Rule - Just Published
Deena
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Diamond Poster
Joined: Dec 2003
Posts: 1,343
Wisconsin
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I have a question . . . it talks about the regulation applying to loans for application received on or before July 30, 2009. I'm assuming that to mean if you receive an application before July 30 but don't close until after July 30, then the regulation applies.
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#1179219 - 05/08/09 03:54 PM
Re: New Reg Z Final Rule - Just Published
CSB98
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Diamond Poster
Joined: Nov 2004
Posts: 2,309
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I think the FRB made an error in the press release. Look at the final rule. See page 31 where it discusses the effective date. It says "for which the creditor receives an application on or after July 30, 2009."
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
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#1179317 - 05/08/09 04:59 PM
Re: New Reg Z Final Rule - Just Published
Reads Regs
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Diamond Poster
Joined: Nov 2004
Posts: 2,309
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I called the FRB and pointed out this issue. They have corrected the press release.
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#1179548 - 05/08/09 06:52 PM
Re: New Reg Z Final Rule - Just Published
Reads Regs
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Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
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Where do you go to get on the distrbution list?
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#1179620 - 05/08/09 07:24 PM
Re: New Reg Z Final Rule - Just Published
ahkcompliance
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Power Poster
Joined: Nov 2001
Posts: 7,985
FINALLY ABOVE the gnat line
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Where do you go to get on the distrbution list? FRB Website
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"Once you learn to read, you will be forever free." - Frederick Douglass
My Opinion Only.
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#1179986 - 05/09/09 10:53 PM
Re: New Reg Z Final Rule - Just Published
David Dickinson
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10K Club
Joined: Jul 2001
Posts: 83,422
Galveston, TX
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It is never over until the fat...... errr, implementation date. However based on the current climate surrounding mortgage lending, I guess I have to admit to being wrong and surprised myself.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1180264 - 05/11/09 03:27 PM
Re: New Reg Z Final Rule - Just Published
rlcarey
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Diamond Poster
Joined: Mar 2003
Posts: 1,035
OK
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Just to make sure I am clear, 226.19(a)2(i) is saying that after the GFE/PTIL are sent our lenders have to wait another 7 days before they can close the loan? And then if something changes in the terms during that 7 day waiting period, they have to redisclose and then wait 3 more days to close the loan?
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#1180376 - 05/11/09 04:15 PM
Re: New Reg Z Final Rule - Just Published
COMPLIcated
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100 Club
Joined: May 2001
Posts: 186
the tundra
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Variable rate loan. Provide early TIL. On our in-house standard ARMs, we "set" the initial rate just days before closing based on the value of the index plus the margin we anticipate being in effect at closing. Index value changes the day before closing. We have to redisclose and wait three more days?
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#1180471 - 05/11/09 05:35 PM
Re: New Reg Z Final Rule - Just Published
COMPLIcated
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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Just to make sure I am clear, 226.19(a)2(i) is saying that after the GFE/PTIL are sent our lenders have to wait another 7 days before they can close the loan? And then if something changes in the terms during that 7 day waiting period, they have to redisclose and then wait 3 more days to close the loan? yes. According to the final rule, both the 7 and the 3 have to expire before closing (closing can be held on that final day) New comment 19(a)(2)-2 clarifies that where corrected disclosures are required consumation may not occur until BOTH the 7-business day and the 3 business day have expired.. Hummm..makes me go back to my original thought...conceivably the closing could still be anytime from the seventh to the 10th day depending on how early the corrected disclosures were given! That's about clear as mud!
Last edited by RR joker; 05/11/09 05:49 PM. Reason: changed thought process
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#1180516 - 05/11/09 06:02 PM
Re: New Reg Z Final Rule - Just Published
RR Joker
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New Poster
Joined: Jan 2009
Posts: 3
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How are other lenders handling application fees in light of the new fee restriction? Face-to-face and Web apps are easily remedied but what about phone apps?
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#1180533 - 05/11/09 06:10 PM
Re: New Reg Z Final Rule - Just Published
RR Joker
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Gold Star
Joined: Aug 2008
Posts: 380
Texas
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but wait... if you MAIL the revised disclosures, you really have to wait an additional 6 days to allow time for the borrower to RECEIVE them 3 days prior to closing, right?
"...comment 19(a)(2)-3 to clarify that the three business- day waiting period before consummation begins when the disclosures are received by the consumer and not when they are mailed.
... if the corrected disclosures are mailed, the consumer is considered to receive the disclosures three business days after mailing."
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#1180599 - 05/11/09 07:01 PM
Re: New Reg Z Final Rule - Just Published
ahanna
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Diamond Poster
Joined: May 2005
Posts: 1,813
Giant side of TX
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but wait... if you MAIL the revised disclosures, you really have to wait an additional 6 days to allow time for the borrower to RECEIVE them 3 days prior to closing, right?
"...comment 19(a)(2)-3 to clarify that the three business- day waiting period before consummation begins when the disclosures are received by the consumer and not when they are mailed.
... if the corrected disclosures are mailed, the consumer is considered to receive the disclosures three business days after mailing." I have not read through the just released Final Rule, but that was one of my initial questions - - Is the 3 bus days "cooling off" after the consumer RECEIVES the corrected disclosure; which would match up with the RESPA changes.
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#1180605 - 05/11/09 07:10 PM
Re: New Reg Z Final Rule - Just Published
ktac MITCH
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100 Club
Joined: May 2001
Posts: 186
the tundra
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That was my read, too. If you mail a revised, wait three days for them to have "received" it and then wait three days for them to really think about it and then you can close. Geez . . . customers are NOT going to like this one little bit.
I think we'll be doing more HELOCs than ever!
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#1180639 - 05/11/09 07:49 PM
Re: New Reg Z Final Rule - Just Published
sammylou
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New Poster
Joined: Jan 2009
Posts: 3
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They way I read the new rule, the question of receipt of the early TIL is only applicable when you are dealing with the fee restriction (i.e. a lender may not charge a fee until the early TIL is received by the consumer). But the date the early TIL or the revised TIL is sent governs when the loan can close.
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#1180667 - 05/11/09 08:07 PM
Re: New Reg Z Final Rule - Just Published
YBRae
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Power Poster
Joined: Nov 2000
Posts: 2,701
PA
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They way I read the new rule, the question of receipt of the early TIL is only applicable when you are dealing with the fee restriction (i.e. a lender may not charge a fee until the early TIL is received by the consumer). But the date the early TIL or the revised TIL is sent governs when the loan can close. I don't believe that's correct. The seven-day waiting period is based on when the early disclosures are delivered or placed in the mail (not when they're received by the consumer), but the loan can't closed until three business days following the consumer's receipt of the corrected TIL (which is assumed to be three business days after the disclosures are mailed).
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#1180677 - 05/11/09 08:11 PM
Re: New Reg Z Final Rule - Just Published
YBRae
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100 Club
Joined: May 2001
Posts: 186
the tundra
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YBRae - I read the three days as relevant in the timing of considering the disclosures "received" when mailing revised disclosures, too. On top of that, you have to wait three days from receipt of an accurate early TIL to close date.
Could be wrong; I'm so messed up between MDIA, the other Reg Z changes for October and the RESPA stuff that may or may not actually go into effect for January. Damn, the next six months are going to suck badly...
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#1180834 - 05/11/09 10:11 PM
Re: New Reg Z Final Rule - Just Published
sammylou
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100 Club
Joined: Jan 2004
Posts: 180
Oklahoma
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Since we are on the subject of Reg. Z, can anyone shed any light on the Repayment Ability section when dealing with 5 year balloons?? All of our mortgages have 15 year amort. with a 5 year maturity. I know the reg states we have to calculate payments 7 years out, correct??
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#1181031 - 05/12/09 01:56 PM
Re: New Reg Z Final Rule - Just Published
rlcarey
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Platinum Poster
Joined: Oct 2006
Posts: 712
PA
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So, is this a true statement?????
Early TILA documents are being amended to add a new required statement onto the document. This change is required under the Mortgage Disclosure Improvement Act, which was a part of the Housing and Economic Recovery Act that was signed by the President on July 30, 2008. The new statement (for both the initial disclosures and corrected disclosures) reads as follows: "You are not required to complete this agreement merely because you have received these disclosures or signed a loan application." This new statement has an effective date of July 30, 2009.
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#1181051 - 05/12/09 02:02 PM
Re: New Reg Z Final Rule - Just Published
2old2care
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100 Club
Joined: Jan 2004
Posts: 180
Oklahoma
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"The Board believes that the reference to an “agreement” is sufficiently clear as a reference to the loan agreement that the disclosures summarize."
From the Federal Reserve Publication.
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"Life isn't about waiting for the storm to pass...it's about learning to Dance in the rain." - Unknown
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#1181163 - 05/12/09 02:53 PM
Re: New Reg Z Final Rule - Just Published
2old2care
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Power Poster
Joined: Nov 2000
Posts: 2,701
PA
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So, is this a true statement?????
Early TILA documents are being amended to add a new required statement onto the document. This change is required under the Mortgage Disclosure Improvement Act, which was a part of the Housing and Economic Recovery Act that was signed by the President on July 30, 2008. The new statement (for both the initial disclosures and corrected disclosures) reads as follows: "You are not required to complete this agreement merely because you have received these disclosures or signed a loan application." This new statement has an effective date of July 30, 2009. Yes, that's a true statement.
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