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#1524201 - 03/18/11 08:58 PM Safe harbor disclosure
Heather301, CRCM Offline
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Joined: Nov 2006
Posts: 105
According to the Federal Reserve Webinar yesterday there is no requirement for a safe harbor disclosure. The only problem with that philosophy is that we just got a newsflash from Wells Fargo stating they are not only going to require a Safe harbor disclosure - but will also require the borrowers signature acknowledging receipt. Has anyone else received this? What are you doing to meet the requirement? Does your vendor offer a disclosure? If not, are you trying to create one on your own?
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Lending Compliance
#1524213 - 03/18/11 09:11 PM Re: Safe harbor disclosure Heather301, CRCM
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 82,469
Galveston, TX
What's a safe harbor disclosure?
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#1524217 - 03/18/11 09:21 PM Re: Safe harbor disclosure rlcarey
Heather301, CRCM Offline
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Posts: 105
It is part of the Regulation Z - Loan Originator Compensation and Steering rule that goes into effect April 1, 2011.
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#1524226 - 03/18/11 10:04 PM Re: Safe harbor disclosure Heather301, CRCM
Working From Home Offline
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Joined: Oct 2009
Posts: 257
Our document vendor has created a special one for us to use (and all the other banks they service).

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#1524302 - 03/21/11 02:32 AM Re: Safe harbor disclosure Heather301, CRCM
Sheldon Hendrix Offline
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Sheldon Hendrix
Joined: Jun 2006
Posts: 1,194
South
Originally Posted By: Heather301
According to the Federal Reserve Webinar yesterday there is no requirement for a safe harbor disclosure. The only problem with that philosophy is that we just got a newsflash from Wells Fargo stating they are not only going to require a Safe harbor disclosure - but will also require the borrowers signature acknowledging receipt. Has anyone else received this? What are you doing to meet the requirement? Does your vendor offer a disclosure? If not, are you trying to create one on your own?


You only need to conern yourself with steering if your bank would be considered a loan originator under the rule. If you fund your loans on your own funds (not table funding or drawing on a LOC), then the steering provisions do not apply.

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#1526408 - 03/24/11 03:12 PM Re: Safe harbor disclosure Sheldon Hendrix
verickson Offline
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Joined: Apr 2009
Posts: 1
If a broker does not receive compensation from the creditor, is a safe harbor disclosure required?

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#1526561 - 03/24/11 05:38 PM Re: Safe harbor disclosure verickson
Snowgirl Offline
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Joined: Sep 2003
Posts: 729
Just to clarify on the steering notice - if it is an in-house loan and we will be funding the loan, we do not need to give the customer a steering notice?

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#1526610 - 03/24/11 06:19 PM Re: Safe harbor disclosure Snowgirl
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,338
If the loan is not going to be retained in house....but to be sold on the secondary market, but we decision and fund it.....no notice either.
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#1526634 - 03/24/11 06:34 PM Re: Safe harbor disclosure swiggles
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
If you do both, fund in-house on held mortgages AND table-fund on the secondary market, but say through only one investor, not multiple...steering notice?
Last edited by RR joker; 03/24/11 06:34 PM.
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#1527791 - 03/28/11 07:29 PM Re: Safe harbor disclosure Working From Home
QCL Offline
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QCL
Joined: May 2002
Posts: 6,259
NW IL
Originally Posted By: Issues1001
Our document vendor has created a special one for us to use (and all the other banks they service).


Our's has too. But is is terrible and I am redoing it smile

I think it contains a lot of information that will be confusing to the borrower and perhaps not required. My research continues...

Does anyone have one they'd consider sharing?

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