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#1776777 - 01/16/13 03:18 PM High Cost Mortgage Rule
raitchjay Online
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In the general rules section, 1026.31, the rule talks about "corrections and unintentional violations". It has 2 different sections, one talking about finding the violation within 30 days and the 2nd finding the violation within 60 days, but the rest of it (what the bank needs to do to avoid having a violation) seems to be identical. So why the need to have the 2 different sections? I must be missing something.....what is the difference in the timing between if the bank finds the violation in 30 days versus 60 days? Thanks.
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HOEPA and Homeowner Counseling Rule
#1777481 - 01/17/13 06:34 PM Re: High Cost Mortgage Rule raitchjay
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I think it is the difference between finding the error at closing or shortly there after and finding the error down the road during an audit, but that is just my take on it.
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#1777483 - 01/17/13 06:37 PM Re: High Cost Mortgage Rule raitchjay
raitchjay Online
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That makes sense and is kinda what i thought: what i don't understand is that the required actions in both scenarios seem identical; therefore, why bother to have 2 sections (one for what to do if you find it within 30 days; the other for what to do if you find it within 60 days), if the required actions in both cases is the same?
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#1777486 - 01/17/13 06:42 PM Re: High Cost Mortgage Rule raitchjay
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That appears to be an accurate assessment of the 30-60 time frames.
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#1777487 - 01/17/13 06:47 PM Re: High Cost Mortgage Rule raitchjay
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raithchjay - You would have to ask Congress, it is the exact way it was written in the Dodd-Frank. The CFPB had no choice.
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#1777489 - 01/17/13 06:49 PM Re: High Cost Mortgage Rule raitchjay
raitchjay Online
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Ok Randy....that's what i was wondering....if this was just typical bureaucratic nonsense or if i was reading it wrong. Thanks.
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#1777690 - 01/17/13 10:11 PM Re: High Cost Mortgage Rule raitchjay
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I re-read it a couple of times, and I think it actually means you either catch the error right away and correct it according to the rule within 30 days of consummation, or if you find it later (say in an audit 6 months down the road), you correct it within 60 days of finding the error. Whenever you find the error, the correction is the same methodology.

...but I may have to read it a few more times to make sure I've got that right.
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#1777693 - 01/17/13 10:15 PM Re: High Cost Mortgage Rule raitchjay
raitchjay Online
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Oh. I'll have to look at it again too. Thanks Tigg.
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#1777697 - 01/17/13 10:17 PM Re: High Cost Mortgage Rule raitchjay
rlcarey Offline
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That is the way that I read it.
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