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#997698 - 07/17/08 01:49 PM
Re: More Job Security - TIL Proposal now finalized?
renniks
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Diamond Poster
Joined: Dec 2003
Posts: 1,362
Wisconsin
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For those of you who are ABA members, they have published a nice nine page summary of the new regulations. It is a good document to use to explain the changes to your CEO or Senior Lender. Where would you find that on the website? I couldn't locate it.
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#997790 - 07/17/08 02:51 PM
Re: More Job Security - TIL Proposal now finalized?
CSB98
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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I couldn't locate it either.
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#997829 - 07/17/08 03:11 PM
Re: More Job Security - TIL Proposal now finalized?
Skittles
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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Just submitted my comprehensive summary to the different areas here...it was all of 1.75 pages long. Only time will tell if/how it will affect us...hard to say until the "average offer on prime loan" figures come out. Our biggest hurdle will be the escrow portion, if it does ends up affecting us.
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My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#997869 - 07/17/08 03:38 PM
Re: More Job Security - TIL Proposal now finalized?
E.E.G.B
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Diamond Poster
Joined: May 2005
Posts: 1,813
Giant side of TX
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From The Fed's Press Release on the new Final Rule for Reg Z - subprime fallout & new category of " Higher Priced " loans " The rule's definition of "higher-priced mortgage loans" will capture virtually all loans in the subprime market, but generally exclude loans in the prime market. To provide an index, the Federal Reserve Board will publish the "average prime offer rate", based on a survey currently published by Freddie Mac. . . . ":: Raises Hand :: Excuse me teacher, but didn't they just close the weekend before The Fed put this out on Monday ??!?!?! Freddie Mac didn't close.... they just got a vote of confidence from the Fed. OOPS - - I am taking a long weekend & I guess my brain had already checked out. I read this at least 3 times & my brain saw INDY Mac every time As Rosanna Rosanadanna would say " NEVER MIND "
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#997927 - 07/17/08 04:09 PM
Re: More Job Security - TIL Proposal now finalized?
E.E.G.B
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Power Poster
Joined: Jan 2008
Posts: 6,389
Looking for My Happy Place....
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They don't mention it, but are they going to have thresholds for mobile homes as well? Reg. Z cover them as principle residences, does it not?
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My opinion only.
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#997971 - 07/17/08 04:44 PM
Re: More Job Security - TIL Proposal now finalized?
Tigg
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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Mobilehomes (manufactured housing) have their own category for escrow requirements and a later compliance date.
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My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#999231 - 07/18/08 06:00 PM
Re: More Job Security - TIL Proposal now finalized?
Tigg
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100 Club
Joined: Nov 2004
Posts: 132
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Our CEO has sent me the following questions about the verification of assets and income:
"Do we have to have a written verification in file? Do you have to verify all of the assets of an applicant? For example, if an applicant has $5 million in various security accounts and 20 rental properties, do you have to verify all? Is there a specific form or method for verification under this law?"
And a question about escrow accounts for in-house first mortgages: "What about the short term loans done to facilitate a permanent mortgage closing?"
I'm signing up for the BOL Webinar in August, but meanwhile, does anyone have any thoughts about what the answers might be?
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#999452 - 07/18/08 07:33 PM
Re: More Job Security - TIL Proposal now finalized?
Auditman
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Power Poster
Joined: Jan 2008
Posts: 6,389
Looking for My Happy Place....
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I read that they will be happy if you use FHA's credit analysis....I printed myself out a copy to see if it's different than what we already do.
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What would you do if you knew you could not fail? ~ Dr. R Schuller
My opinion only.
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#999464 - 07/18/08 07:46 PM
Re: More Job Security - TIL Proposal now finalized?
Auditman
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Gold Star
Joined: Apr 2006
Posts: 275
Beach Bum, East Coast, USA
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"Do we have to have a written verification in file? Do you have to verify all of the assets of an applicant? For example, if an applicant has $5 million in various security accounts and 20 rental properties, do you have to verify all? Is there a specific form or method for verification under this law?"
And a question about escrow accounts for in-house first mortgages: "What about the short term loans done to facilitate a permanent mortgage closing?"
All it says is verify & document, so I'm sure you could notate the file, etc.... Also, loans not covered: Home equity lines of credit, reverse mortgages, construction-only loans, Bridge loans, "business purpose" loans.. Your example sounds like a Bridge loan to me
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#999779 - 07/19/08 01:49 AM
Re: More Job Security - TIL Proposal now finalized?
Pickles
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10K Club
Joined: Aug 2002
Posts: 47,673
Bloomington, IN
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All it says is verify & document, so I'm sure you could notate the file, etc Due to quarter end reviews and other projects I have not yet read this thoroughly, but notating something in the file would not, IMO, be sufficient to document that you have verified income, deposits, or whatever without documentation to support that notation. Heck I could notate in the file I verified Jane's accounts to be $55,000 but without documentation I may have only verified the account to me $55 and my $55,000 notation was either an out right lie to trump up the loan or a legitimate decimal point error.
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The opinions expressed are mine and they are not to be taken as legal advice.
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#1103648 - 12/30/08 04:47 PM
Re: More Job Security - TIL Proposal now finalized?
Dan Persfull
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Platinum Poster
Joined: Aug 2006
Posts: 980
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Does anyone know what the status is on the index the Fed is publishing? I'd like to see where our in-house mortgages are going to fall BEFORE the mandatory compliance date (we charge some pretty high interest rates IMO, so I'm nervous)
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#1104006 - 12/30/08 09:44 PM
Re: More Job Security - TIL Proposal now finalized?
MN Banker
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Platinum Poster
Joined: Jul 2005
Posts: 961
Lost in a regulatory fog
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I haven't seen anything, but the rates on which they plan to base the index are available here, Freddie Mac That should give you a precusory idea of where you stand.
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#1104175 - 12/31/08 02:14 PM
Re: More Job Security - TIL Proposal now finalized?
David Dickinson
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100 Club
Joined: Oct 2002
Posts: 107
Alexandria, VA
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I have been looking for the new rule to be published in the Fed. Reg. but haven't seen it yet. Did I overlook it?
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#1104197 - 12/31/08 02:56 PM
Re: More Job Security - TIL Proposal now finalized?
JimK
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Gold Star
Joined: Sep 2003
Posts: 273
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If i did this correctly, here is the Final Regulation from the Federal Register. If not try searching the Federal Register website for: page 44522 Vol. 73, No. 147
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