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#997668 - 07/17/08 01:29 PM Re: More Job Security - TIL Proposal now finalized? E.E.G.B
renniks Offline
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renniks
Joined: Sep 2003
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New England
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.

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#997698 - 07/17/08 01:49 PM Re: More Job Security - TIL Proposal now finalized? renniks
CSB98 Offline
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Wisconsin
Originally Posted By: renniks
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
Skittles Offline
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TN
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
RR Joker Offline
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The Swamp
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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#997863 - 07/17/08 03:33 PM Re: More Job Security - TIL Proposal now finalized? Skittles
renniks Offline
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renniks
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New England
I got to it through a link on ABA Newsbytes on July 15th. This is the link, though I don't know if it will work.

http://www.aba.com/Compliance/mortgage_reform.htm

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#997869 - 07/17/08 03:38 PM Re: More Job Security - TIL Proposal now finalized? E.E.G.B
ktac MITCH Offline
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ktac MITCH
Joined: May 2005
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Giant side of TX
Originally Posted By: Empress EGB
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.



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
Tigg Offline
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Looking for My Happy Place....
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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#997971 - 07/17/08 04:44 PM Re: More Job Security - TIL Proposal now finalized? Tigg
RR Joker Offline
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The Swamp
Mobilehomes (manufactured housing) have their own category for escrow requirements and a later compliance date.
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#998545 - 07/17/08 11:00 PM Re: More Job Security - TIL Proposal now finalized? RR Joker
Tigg Offline
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Looking for My Happy Place....
Thanks, Joker. I forgot....I read it but my brain is mush!
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#999231 - 07/18/08 06:00 PM Re: More Job Security - TIL Proposal now finalized? Tigg
Auditman Offline
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Joined: Nov 2004
Posts: 132
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
Tigg Offline
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Tigg
Joined: Jan 2008
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Looking for My Happy Place....
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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#999464 - 07/18/08 07:46 PM Re: More Job Security - TIL Proposal now finalized? Auditman
Pickles Offline
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Beach Bum, East Coast, USA
Originally Posted By: Auditman
"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
Dan Persfull Offline
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Bloomington, IN
Quote:
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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#1103648 - 12/30/08 04:47 PM Re: More Job Security - TIL Proposal now finalized? Dan Persfull
MN Banker Offline
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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
Carolina Blue Offline
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Carolina Blue
Joined: Jul 2005
Posts: 958
Lost in a regulatory fog
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
JimK Offline
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Alexandria, VA
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
lblu Offline
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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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#1104473 - 12/31/08 08:11 PM Re: More Job Security - TIL Proposal now finalized? lblu
Dollye7 Offline
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Dollye7
Joined: Jun 2006
Posts: 255
Southwest USA
I got an error message on that link. This should get you there.

http://edocket.access.gpo.gov/2008/E8-16500.htm

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