Financial Institutions have been calculating the total of points and fees for years to determine whether a transaction is a high-cost mortgage loan (Section 32). Most lenders have few, if any, high-cost mortgages so calculating the points and fees has not been a high priority.
But now the game is changing. The calculation of points and fees is changing. The calculation is both more important and more complicated. It is not enough to know how to calculate the number; now it is also important to understand how to manage the number.
With the new calculation and lower thresholds the volume of high-cost mortgages is going to increase. Plus the points and fees number has renewed importance. The number will soon be reported on the HMDA LAR. It is also used to determine whether a transaction is compliant with various new fee caps.
The calculation of points and fees has never been more important or complicated. This program explains when and how the points and fees are calculated and how to manage the number.
Participants receive a detailed manual that serves as a handbook long after the program is completed
Upon completion of this two-hour program, participants understand:
- What items are included in the calculation of points and fees
- What items may be excluded from the calculation
- When and how is the total of points and fees is used under currently effective rules and in rules that will unfold over the next several months
- How to manage points and fees to avoid fee cap violations under the
- General ability to repay standards contained in Section 1026.43 (c)(2)
- "Standard mortgage" rules contained in Section 1026.43(d)(1)(ii)
- "Qualified mortgage" rules contained in Section 1026.43(e)(2)
- "Special qualified mortgage" rules contained in Section 1026.43(3)(4)(i)
- "Balloon-payment qualified mortgage" rules contained in Section 1026.43(f)(1) and
- "Small creditor portfolio loan" rules contained in new Section 1026.43(e)(5)(i)
The program is designed for managers, loan originators, loan officers, lending assistants, compliance officers, auditors and others with responsibilities related to originating mortgage loans.