Thread Options
|
#1557271 - 05/26/11 05:20 PM
Regulation Z - Abiilty to Repay Proposal
|
Power Poster
Joined: Oct 2009
Posts: 3,927
|
There's an Outlook Live Webinar today by the FRB on the above topic. I'm not sure if it's going to be available in an archived version, but if anyone attends it would be appreciated if you could post any significant news. I've got a copy of the slides, but that's sometimes only half the story.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius
|
Return to Top
|
|
|
|
#1557435 - 05/26/11 07:21 PM
Re: Regulation Z - Abiilty to Repay Proposal
Doug Hendrickson
|
Diamond Poster
Joined: Sep 2008
Posts: 2,473
Midwest
|
I listned to it. Didn't learn too much. I concentrated on Compliance Option #3: Balloon-Payment Qualified Mortage as that is all we do. From what I get, a 3 year balloon will be out, only can do 5 year. My thing I am trying to figure out now is the list of counties the Board approves as rural or underserved as that is a requirement for that option. They really didn't deviate much from the slides.
|
Return to Top
|
|
|
|
#1557445 - 05/26/11 07:30 PM
Re: Regulation Z - Abiilty to Repay Proposal
ahkcompliance
|
Power Poster
Joined: Oct 2009
Posts: 8,956
OK
|
Most convoluted, rambling bit of proposed rulemaking i've had the displeasure to sit through so far.
_________________________
I'm fixin' to fix that.
|
Return to Top
|
|
|
|
#1557503 - 05/26/11 08:25 PM
Re: Regulation Z - Abiilty to Repay Proposal
ahkcompliance
|
Platinum Poster
Joined: Nov 2004
Posts: 500
Central Illinois
|
Definitions of Rural or Underserved A county is desiginated as “rural” if it is categorized under ERS urban influence code 7, 10, 11, or 12. http://www.ers.usda.gov/Data/UrbanInfluenceCodes/2003/7 out of 102 counties in Illinois have these codes. The test for “underserved” in proposed § 226.43(f)(2)(ii), described above, is based on the Board’s judgment that, where no more than two creditors are significantly active(measured by extending mortgage credit at least five times in a year) 2 of the 7 counties in Illinois have less than 3 banking offices
|
Return to Top
|
|
|
|
#1557529 - 05/26/11 08:49 PM
Re: Regulation Z - Abiilty to Repay Proposal
Oursisnottoreasonwhy
|
Power Poster
Joined: Aug 2002
Posts: 3,094
|
I listened, but still don't understand why this rule has to be so complicated.
_________________________
Opinions are my own and not of my employer.
|
Return to Top
|
|
|
|
#1557539 - 05/26/11 08:57 PM
Re: Regulation Z - Abiilty to Repay Proposal
Oursisnottoreasonwhy
|
Power Poster
Joined: Nov 2003
Posts: 3,719
|
So consumers can sue the bank years later claiming that the bank should have known when they made the loan that the consumer wasn't going to be able to pay it back. That's what I got out of it too - assuming they go with the rebuttable presumption of compliance or whatever it what is called.
_________________________
It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.
|
Return to Top
|
|
|
|
#1557584 - 05/26/11 10:26 PM
Re: Regulation Z - Abiilty to Repay Proposal
Peach
|
Power Poster
Joined: Aug 2001
Posts: 7,336
|
Rant away, Peach.....won't bother any of us.
_________________________
The more you sweat in training, the less you bleed in battle.......
|
Return to Top
|
|
|
|
#1557702 - 05/27/11 01:28 PM
Re: Regulation Z - Abiilty to Repay Proposal
swiggles
|
Platinum Poster
Joined: Aug 2010
Posts: 528
|
Another piece of misguided legislation that will ultimately restrict mortgage-secured credit and hurt the very same consumers they were attempting to help. Maximum 80% LTV on a purchase QRM with no gift nor PMI allowed (nor piggyback financing) - ??? - I think I remember seeing one of those loans but it was a LONG time ago...!
|
Return to Top
|
|
|
|
#1557775 - 05/27/11 02:42 PM
Re: Regulation Z - Abiilty to Repay Proposal
Oursisnottoreasonwhy
|
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
|
Definitions of Rural or Underserved A county is desiginated as “rural” if it is categorized under ERS urban influence code 7, 10, 11, or 12. http://www.ers.usda.gov/Data/UrbanInfluenceCodes/2003/7 out of 102 counties in Illinois have these codes. The test for “underserved” in proposed § 226.43(f)(2)(ii), described above, is based on the Board’s judgment that, where no more than two creditors are significantly active(measured by extending mortgage credit at least five times in a year) 2 of the 7 counties in Illinois have less than 3 banking offices So basically 99% of banks don't fall into these areas and can forget about that option for compliance. This really hurts small banks - regardless of whether they are located in these rural or underserved areas.
|
Return to Top
|
|
|
|
#1557933 - 05/27/11 04:27 PM
Re: Regulation Z - Abiilty to Repay Proposal
AuditorK
|
100 Club
Joined: Dec 2009
Posts: 173
|
Ditto to all! This proposal is absolutely ridiculous on many levels. It seems like landmines are being put in the way of banks so that even when compling with these confusing options, bankers will still trip up and end up reimbursing consumers or paying huge fines. Don't they realize that this could end up hurting the consumer even more if banks decide to get out of consumer mortgage lending or if banks' credit standards are tightened so that only an elite category of borrowers are able to borrow money?
I think I need to start my second career at my local lawn and garden store!
|
Return to Top
|
|
|
|
#1557982 - 05/27/11 05:10 PM
Re: Regulation Z - Abiilty to Repay Proposal
Luvinit
|
Power Poster
Joined: Aug 2001
Posts: 7,336
|
I think I need to start my second career at my local lawn and garden store! That's what I've ALWAYS wanted to do!! No better time than the present!!!
_________________________
The more you sweat in training, the less you bleed in battle.......
|
Return to Top
|
|
|
|
#1558068 - 05/27/11 06:13 PM
Re: Regulation Z - Abiilty to Repay Proposal
swiggles
|
Diamond Poster
Joined: Dec 2008
Posts: 1,268
|
We must all admit that we've been through some troubling times in the past few years. I remember sitting in on a presentation about piggy back loans up to 125% ltv years ago and thinking it was a crazy idea. And, hey, what about NINAs and the rest of the stated or non stated incomes? I also remember disqualifying a loan because it was supposed to be a NINA and I accidentally put pay stubs in the file! I don't know how the rest of you feel, but things had to change because the bubble popped. What I gathered from the Webinar is we're going back to 80% loans and all that goes with them. They're back....
|
Return to Top
|
|
|
|
#1558075 - 05/27/11 06:18 PM
Re: Regulation Z - Abiilty to Repay Proposal
swiggles
|
10K Club
Joined: Sep 2002
Posts: 13,965
TN
|
That's my husband's retirement plan. Selling petunias to little old ladies - or he wants to volunteer at the Smokey Mountain National Park. He's a banker, too.
_________________________
My Opinions Only
|
Return to Top
|
|
|
|
#1558101 - 05/27/11 06:36 PM
Re: Regulation Z - Abiilty to Repay Proposal
Skittles
|
Power Poster
Joined: Aug 2001
Posts: 7,336
|
Not to hijack this thread....but I was planning on a visit to the Great Smokies...never been there. But I could not get a reservation at the lodge to which I wanted hike....Leconte Lodge. You can only get there on foot...shortest distance, 5 miles.
_________________________
The more you sweat in training, the less you bleed in battle.......
|
Return to Top
|
|
|
|
|
|