Skip to content
BOL Conferences
Page 1 of 2 1 2
Thread Options
#989568 - 07/08/08 03:10 PM More Job Security - TIL Proposal now finalized?
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Sounds like the TIL proposal has been finalized and being issued next week (see paragraph 3). Should be interesting to see how bad it will end up.

http://www.federalreserve.gov/newsevents/speech/bernanke20080708a.htm

The recent experience, including the broader turmoil we have seen in the financial markets, will have--indeed, is already having--important consequences for U.S. regulatory policy. First, regulators are taking action to strengthen consumer protections. Next week, the Federal Reserve Board will issue new rules on mortgage lending, using its authorities under the Home Ownership and Equity Protection Act. These new rules, which will apply to all lenders and not just banks, will address some of the problems that have surfaced in recent years in mortgage lending, especially high-cost mortgage lending. We received many helpful comments on our proposal and we incorporated a number of them into the final rules. In another effort to protect consumers, the Board has also recently issued proposals to substantially improve credit card disclosures and to address a number of unfair or deceptive acts and practices in credit card lending.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top
Lending Compliance
#989628 - 07/08/08 03:33 PM Re: More Job Security - TIL Proposal now finalized? David Dickinson
ktac MITCH Offline
Diamond Poster
ktac MITCH
Joined: May 2005
Posts: 1,813
Giant side of TX
Originally Posted By: David Dickinson
Sounds like the TIL proposal has been finalized and being issued next week (see paragraph 3). Should be interesting to see how bad it will end up.
. . . We received many helpful comments on our proposal and we incorporated a number of them into the final rules. . . [/b][/i]


Thanks for the heads up David.
I'm keeping my fingers crossed that they did listen to input and the new category of "High Cost" but not "HOEPA High"
didn't make it to the final.
_________________________
My opinions are just that, and might be worth what you paid for them.

Return to Top
#994380 - 07/14/08 03:25 PM Re: More Job Security - TIL Proposal now finalized? ktac MITCH
ktac MITCH Offline
Diamond Poster
ktac MITCH
Joined: May 2005
Posts: 1,813
Giant side of TX
SO - - The final rule is now out. here is draft for the Fed Register
Which Guru will be first to weed through the 419 pages and give us the scoop?
_________________________
My opinions are just that, and might be worth what you paid for them.

Return to Top
#994401 - 07/14/08 03:37 PM Re: More Job Security - TIL Proposal now finalized? ktac MITCH
Dollye7 Offline
Gold Star
Dollye7
Joined: Jun 2006
Posts: 255
Southwest USA

Return to Top
#994403 - 07/14/08 03:37 PM Re: More Job Security - TIL Proposal now finalized? ktac MITCH
Reads Regs Offline
Diamond Poster
Joined: Nov 2004
Posts: 2,307
_________________________
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

Return to Top
#994430 - 07/14/08 03:51 PM Re: More Job Security - TIL Proposal now finalized? Reads Regs
waldensouth Offline
Power Poster
waldensouth
Joined: Nov 2001
Posts: 7,983
FINALLY ABOVE the gnat line
ARGHHHHHhhhhhhhhh!!!!!
_________________________
"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

Return to Top
#994560 - 07/14/08 05:13 PM Re: More Job Security - TIL Proposal now finalized? waldensouth
Tigg Offline
Power Poster
Tigg
Joined: Jan 2008
Posts: 6,389
Looking for My Happy Place....
I've started reading. Did someone once say suicide is painless.....I may need to check into this option. ESCROWS!!!!!
_________________________
What would you do if you knew you could not fail? ~ Dr. R Schuller

My opinion only.

Return to Top
#994692 - 07/14/08 06:26 PM Re: More Job Security - TIL Proposal now finalized? Tigg
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
only for high cost rider...just high cost...calm down.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#994695 - 07/14/08 06:27 PM Re: More Job Security - TIL Proposal now finalized? RR Joker
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
anybody got the quick link to the original proposal (I've got examiners and didn't want to take the time to dig if someone could just magically put it out here...I can't remember what they WERE proposing on YSP's and now I'm curious.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#994700 - 07/14/08 06:30 PM Re: More Job Security - TIL Proposal now finalized? RR Joker
E.E.G.B Offline
Power Poster
E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
Disclosure, I think - if you've ever read any of the state level high cost laws, it's not dissimilar. It's actually more benevolent than a lot of those.
_________________________
I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.

Return to Top
#994702 - 07/14/08 06:30 PM Re: More Job Security - TIL Proposal now finalized? RR Joker
E.E.G.B Offline
Power Poster
E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
sorry - double post.
Last edited by Empress EGB; 07/14/08 06:30 PM.
_________________________
I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.

Return to Top
#994707 - 07/14/08 06:35 PM Re: More Job Security - TIL Proposal now finalized? RR Joker
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Originally Posted By: RR joker
only for high cost rider...just high cost...calm down.

But it will cover MANY conventional loans. The magical issue is the new index the FRB is creating. We don't know what it will be. The proposal indicated to use 3/5% over the H-15 report. Speaking with several clients indicated this would capture up to 80% of their mortgage loan portfolios. Hopefully, the new index will be high as the final rule uses 1.5/3% (off the top of my head). This could be devastating.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top
#994719 - 07/14/08 06:40 PM Re: More Job Security - TIL Proposal now finalized? David Dickinson
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
That's the key David...somehow I have a feeling our FI will rule in the NO HIGH COSTS LOANS...whatever it takes to do so.

Oh..and never mind about the original proposal...the "short-version" has what I needed in it.

thanks!
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#994840 - 07/14/08 07:41 PM Re: More Job Security - TIL Proposal now finalized? RR Joker
swiggles Offline
Power Poster
swiggles
Joined: Aug 2001
Posts: 7,351
Our biggest hurdles will be that if our in-house mortgages get pulled into the "high price" group, we'll have to:

  • document the borrower's ability to repay (however THAT'S to be accomplished)
  • not consider income that we don't verify
  • escrow for taxes and insurance for 1st lien loans (we do not currently escrow for in-house mortgages....we don't have very many of these)
and for all loans secured by the borrower's principal dwelling, we'll have to:

  • provide a TIL prelim for loans that heretofore were not included in the requirement
_________________________
The more you sweat in training, the less you bleed in battle.......

Return to Top
#994844 - 07/14/08 07:43 PM Re: More Job Security - TIL Proposal now finalized? swiggles
E.E.G.B Offline
Power Poster
E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
A lot of my banks give early TILs anyway - they find it easier to train the lending staff to just hand those out, regardless of type/purpose for RE loans. So that one I don't see as too much of a problem. The escrows one I think is going to be tricky. I'm waiting to see the index, of course.
_________________________
I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.

Return to Top
#994876 - 07/14/08 08:10 PM Re: More Job Security - TIL Proposal now finalized? E.E.G.B
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
sWIGGLES, your documentation to support repayment should just be income verification/job stability to justify appropriate DTI ratios...shouldn't be a big hurdle. Now servicing (escrows) for those who do not currently do so, that could be interesting.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#994982 - 07/14/08 09:16 PM Re: More Job Security - TIL Proposal now finalized? ktac MITCH
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
Originally Posted By: ktac MITCH

Which Guru will be first to weed through the 419 pages and give us the scoop?


Well you know we'll be covering this at our Oct. loan conference.

http://www.bolconferences.com/lcdc/
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#995035 - 07/14/08 10:18 PM Re: More Job Security - TIL Proposal now finalized? RR Joker
Tigg Offline
Power Poster
Tigg
Joined: Jan 2008
Posts: 6,389
Looking for My Happy Place....
Originally Posted By: RR joker
..... Now servicing (escrows) for those who do not currently do so, that could be interesting.


That's why I was not calm. Is a year and a half long enough to get escrow set up and get everyone trained?
_________________________
What would you do if you knew you could not fail? ~ Dr. R Schuller

My opinion only.

Return to Top
#997010 - 07/16/08 07:14 PM Re: More Job Security - TIL Proposal now finalized? Tigg
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
If you begin now! It's a PITA tho...it's been quite a number of years since I was involved in those day-to-day issues.

Any idea on when this new index will be revealed so we will have a better idea of how bad to panic????????????
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#997045 - 07/16/08 07:27 PM Re: More Job Security - TIL Proposal now finalized? RR Joker
ktac MITCH Offline
Diamond Poster
ktac MITCH
Joined: May 2005
Posts: 1,813
Giant side of TX
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 ??!?!?!
_________________________
My opinions are just that, and might be worth what you paid for them.

Return to Top
#997307 - 07/16/08 10:23 PM Re: More Job Security - TIL Proposal now finalized? ktac MITCH
Tigg Offline
Power Poster
Tigg
Joined: Jan 2008
Posts: 6,389
Looking for My Happy Place....
I'm feeling so much better about all this.....
_________________________
What would you do if you knew you could not fail? ~ Dr. R Schuller

My opinion only.

Return to Top
#997338 - 07/16/08 11:24 PM Re: More Job Security - TIL Proposal now finalized? Tigg
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
The escrow problem will depend on how many loans you have and your systems capabilities. A few wouldn't be hard, but would be a PITA. A lot would be a problem and be a PITA for several people.

Also consider the customer with a lien-free home. They want a HELOC or improvement loan. Nothing big. But if you do it, you'll be first lien. Escrow. Ugg.

But hey, I'm betting as we begin to better understand all of this, we'll realize there are plenty more problems.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#997343 - 07/16/08 11:36 PM Re: More Job Security - TIL Proposal now finalized? Andy_Z
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
Also, I think you have until 04-2010 for escrows. Heck, with all that time you could...

- switch positions
- hope the rules change again
- attend a BOL webinar on the topic and just get it like you've gotten the changes before it to everything else we do.
Last edited by Andy Z; 07/16/08 11:38 PM.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#997365 - 07/17/08 12:06 AM Re: More Job Security - TIL Proposal now finalized? Andy_Z
Tigg Offline
Power Poster
Tigg
Joined: Jan 2008
Posts: 6,389
Looking for My Happy Place....
Andy, You just make it seem all better!!


(thanks for the smile!)
_________________________
What would you do if you knew you could not fail? ~ Dr. R Schuller

My opinion only.

Return to Top
#997505 - 07/17/08 03:00 AM Re: More Job Security - TIL Proposal now finalized? ktac MITCH
E.E.G.B Offline
Power Poster
E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
Originally Posted By: ktac MITCH
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.
_________________________
I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.

Return to Top
Page 1 of 2 1 2

Moderator:  Andy_Z