I was wondering the same thing.

Does anyone have an advertising checklist that includes the Oct. 1 changes on it?

Does anyone want to develop forms and train my people for me? I swear I met myself in the hallway a little earlier. I feel like I'm going in circles.

I have this sign that I think I need to dig out and put on my desk:

I'm Lost
I've gone to look for Myself.
If I should return before I get back,
Please ask me to wait!!

I've created an HPML worksheet that walks the lender thru step by step. I've sent it to Michele to have it added to the Banker's Tools section. Hopefully you will find it useful.

I have to prepare Audit Committee Reports, but will work on an Advertising checklist as soon as that's finished. Maybe one of you will beat me to it!

We had our training this past Tuesday...while in the midst of a 3-week S&S exam...it went well...we'll see how it goes once it's implemented!

I am new to these threads. I have read through this thread and have been unable to find help with this, so I apologize if it has already been asked. Can someone please explain how to use the FFIEC rate spread site in order to determine if you are going to have a higher priced mortgage loan? I know that there are fixed rate and variable rate APOR tables, and there is also a rate spread calculator that you will begin using for applications taken on or after October 1. I need to be able to explain to our employees how to determine if they have a higher priced mortgage loan by using the APR on the preliminary TIL. Thanks for your help!

The P ETIL will be a good early tool to see if you have a potential HPML but keep in mind you have to use the "final" (when the rate is last set) APR.

The calculator actually has a pretty decent help section. Just click on the help link.

If the APR is within the threshold (1.5/3.5) the result will show NA. If it is outside the threshold then it will show the spread as 1.62 or whatever the figure happens to be. So as long as the result comes back as NA you would not have a HPML.

Thank you for your help Dan!

Walden,

Thanks for your willingness to share!!!!!!!

Has it been added yet? I did not see in Bankers Tools.

Michele was sending it to Andy for review before adding it. I did find 1 "oops" after I sent it in.

Ok, I'm freaking out a little bit. Just when I thought we were doing OK on getting the new Reg Z changes implemented, I read the letter to the Fed, FHA, GNMA, etc. regarding interest charged at payoff being considered a prepayment penalty.

http://www.aba.com/aba/documents/news/FHAloans92509.pdf

Why did this letter come out one week before the implementation date? This has serious implications.

So is everyone going to stop offering higher-priced FHA loans as of Thursday?

We have a meeting at 2:00 p.m. to discuss. We are checking with MBA to learn more about their interpretation (which differs from ours). If the industry indeed interprets this interest as a prepayment penalty, then yes, we will halt any higher priced loans on Thursday until the issue is resolved.

I just check on a recent FHA loan that we made - It was for only $90,000 and the APR was only .53 higher than the interest rate on the note. (of course larger loan would have less of an increase in the apr).

As of today the 30Yr APOR is 5.09 and we locked an FHA loan on the secondary market today at 5.125 with no points. So the APR should be somewhere around 5.5 or 5.6 and that is below the HPML threshold of 6.59 { APOR 5.09 plus 1.5 }

What would have to be included / happen to push your FHA loans into the HPML territory ??, other than a small loan amount.

The FRB has issued a Consumer Affairs letter dated 9/21/09 that transmits revised Reg. Z exam procedures that incorporate the 10/1/09 changes.

Here's a link to the letter.
http://www.federalreserve.gov/boarddocs/caletters/2009/0909/caltr0909.htm

Here's a link to the 77 page exam procedures document.
http://www.federalreserve.gov/boarddocs/caletters/2009/0909/09-9_attachment.pdf

Does anyone have a link to the under lying rate tables?

Well duh, I saw the calculators and not the tables. Thanks,

I had this question come up at the bank so I thought I would ask it here.

We have a workout loan that was done previously as a balloon and it will come due next year. The loan is paying as agreed. When it comes due next year and we calcluate their ability to repay based on these new procedures (the current rate would be considered a HPML), what options do we have if they do not meet our DTI calculations?

Thanks,

Joe,
I asked a similar question earlier - and was told that you can't renew as a HPML is there is no ability to pay. Options were to lower rate or foreclose (assuming you can't just have them refinance elsewhere)

I ditto that good question from Joeball!

1. Regarding Temp Financing, at maturity, (12 months), can we extend the loan and have it still be out of the range of HPML? I certainly understand that structing loans to look like temp financing could be an issue, but in the cases of a house not selling, or other reasons for which it was temp in the first place did not come to fruition, can we extend a temp loan and still be exempt from HPML rules?

2. REgarding third party verification of assets relied upon when determining repayment ability, can our Credit Administration Office, (prepares docs, evaluations, orders appraisals, reviews appraisals, is independent of the lending area), prepare evaluations for third party verification purposes?

Thanks,

Deb

We also have some workouts that we are not ready to foreclose yet. You can extend or modify --- no new note! Not a new note, HPML does not apply.

Not to be a way around the rules, just don't want to be a 1 strike and you're out. I really don't think congress was planning on us foreclosing on existing loans if we could get them worked out. Need to set some guidelines in your policy, this is temporary.

I disagree you can't "renew". If you don't refinance the loan, it's not subject to Reg Z disclosures. I think this is "legally" circumventing. It may also not be looked kindly on by examiners, but is legal.