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#1193793 - 06/01/09 06:06 PM 07/30 MDIA --- Only Closed-End FIXED Mortgages ??
BLPage Offline
100 Club
Joined: Jan 2006
Posts: 222
Virginia
Is it correct that MDIA effective July 30th will cover only closed-end fixed mortgages? Variable-rate/ARMS are not part of this new regulation until later on in the year?

We only make 3 or 4 closed-end fixed mortgages a month. Most are closed-end variables {5/360's}, so this would be of huge help if it is correct.

Thank you for confirmation advice.

P.S. We are all geared up and ready for BOL's webinar on June 9th, "The New Early Truth in Lending Disclosures", and confirming 'fixed only' will let us sleep a bit better.

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#1193818 - 06/01/09 06:27 PM Re: 07/30 MDIA --- Only Closed-End FIXED Mortgages ?? BLPage
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
Sorry to bust your hopes..but it affects all closed-end loans secured by a consumer's dwelling. (IOW, not just principal ones anymore)
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1193819 - 06/01/09 06:28 PM Re: 07/30 MDIA --- Only Closed-End FIXED Mortgages ?? BLPage
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,610
Bloomington, IN
Unless I missed something I'm not aware that ARM loans and other variable rate closed-end mortgage loans subject to Reg Z are exempt.

There will be some additional ARM disclosure requirements that will become effective in 2011 but to the best of my knowledge all closed-end residential mortgage loans subject to Reg. Z will be covered by the requirements of MDIA beginning 7/30/09.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1193870 - 06/01/09 07:06 PM Re: 07/30 MDIA --- Only Closed-End FIXED Mortgages ?? Dan Persfull
BLPage Offline
100 Club
Joined: Jan 2006
Posts: 222
Virginia
I knew that it was for fixed and ARMs, but then I read the
following sentence and placed the emphasis on the wrong words:

"The MDIA also contains additional disclosure requirements for variable-rate transactions that are not addressed in this rulemaking."

I placed it on 'for variable-rate transactions' rather than 'additional'. Sometimes it is just so hard to read these rules. Interpreting one word or phrase incorrectly can be disasterous. Thank you for putting me back to where I was !!!

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#1194010 - 06/01/09 08:33 PM Re: 07/30 MDIA --- Only Closed-End FIXED Mortgages ?? BLPage
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
It was really just wishfull thinking on your park, Page! wink

But, you are so right...one word incorrectly emphasized or interpreted can make or break you really fast~!
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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