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#2100947 - 09/29/16 01:30 PM
Use of 2016 URLA
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Gold Star
Joined: May 2015
Posts: 288
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The CFPB approved the use of the new URLA for applications in 2017 and allowed lenders to begin collecting the new monitoring data at that same time. Sounds to me like this will be a big help in preparing for the HMDA changes in 2018. https://www.federalregister.gov/document...d-home-mortgage
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#2100976 - 09/29/16 03:06 PM
Re: Use of 2016 URLA
ComplyGuy
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Gold Star
Joined: May 2015
Posts: 288
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I think this will help speed up the vendors preparedness. With this ruling now they could implement before 2018. Without it, I wouldn't have been expected to implement until 2018 and then there would be problems when . This gives time to work out the kinks.
What legal risks do you foresee? Potential for fair lending violations?
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#2101294 - 09/30/16 06:54 PM
Re: Use of 2016 URLA
ComplyGuy
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Gold Star
Joined: Dec 2006
Posts: 435
TN
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Does anyone have any thoughts about whether the new URLA will be required (or considered best practice) for consumer-purpose home equity and/or HELOCs? We use the current version only in our residential lending division that engages in secondary market activity. The equity and HELOC loans use a version of the ECOA model form generated off LaserPro.
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#2102544 - 10/11/16 05:47 PM
Re: Use of 2016 URLA
ComplyGuy
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100 Club
Joined: Jul 2011
Posts: 238
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I don't see where the co-borrowers information is collected. Do we need to use a separate application for the co-borrower information?
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#2102552 - 10/11/16 06:16 PM
Re: Use of 2016 URLA
ComplyGuy
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100 Club
Joined: May 2009
Posts: 231
midwest
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On page 11 of the linked document, there is a section for 'Additional Borrower' - I think that's what you are looking for.
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CRCM
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#2102558 - 10/11/16 06:34 PM
Re: Use of 2016 URLA
ComplyGuy
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100 Club
Joined: Jul 2011
Posts: 238
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Thank you.
So the co-applicant has to fill out a separate application. Interesting and very time consuming. How many people will just say "see" or "same" as borrower application.
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#2102607 - 10/11/16 08:14 PM
Re: Use of 2016 URLA
ComplyGuy
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100 Club
Joined: May 2009
Posts: 231
midwest
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It isn't actually a separate application - several of the sections say information was included on applicants application - it's more the co-applicants personal info, employment info and gmi. The co-applicant signature line is on the primary applicants form.
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CRCM
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#2105094 - 10/28/16 04:02 PM
Re: Use of 2016 URLA
Kathleen O. Blanchard
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Diamond Poster
Joined: May 2011
Posts: 1,984
Idaho
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Just FYI because Fannie/Freddie is "un-issuing" the form on November 1 pending implementation. I heard back from them today (I had asked about using a paper form for in house loans, for example).
For non GSE loans, you can start to use the new form in 2017. So if you want to use it in paper form or you have a vendor who is ready, it is allowed for non GSE loans only.
Has Fannie/Freddie put anything out to this effect, or are we just awaiting an announcement on 11/1? My CO is looking for something to back this up. Thanks!
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All opinions are my own, not my employer's
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#2105684 - 11/02/16 04:12 PM
Re: Use of 2016 URLA
ComplyGuy
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Platinum Poster
Joined: Apr 2014
Posts: 673
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Thank you so much Kathleen.
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