Saturday, December 16, 2017

Coping with HOPA

Posted by Tom January 19, 2015 4:57pm
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On February 25, 2014, the FDIC released its revised interagency consumer compliance exam procedures for the mortgage rules that became effective with the Dodd-Frank Act. The focus of the issuance of the procedures is part of the FDIC's efforts to inform affected banks about bank regulatory developments in hopes of creating a better dialogue between the FDIC and the institutions it...

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Coping with the CFPB’s Ability-to-Repay Rule

Posted by Tom January 19, 2015 4:43pm
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On January 10, 2013, the Consumer Financial Protection Bureau (“CFPB”) released its final Ability-to-Repay (“ATR”) and Qualified Mortgage Rule, effective January 10, 2014. Our Subject Matter Experts in our Regulatory...

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Appraisal Disclosure Rule

Posted by Tom November 26, 2014 2:01pm
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Effective January 8, 2014, the new Rules on providing appraisals and other valuations went live in accordance with the Dodd-Frank amendments to Reg B, commonly referred to as the ECOA Valuations Rule. When something relatively significant like this goes into effect, there can be some confusion as to what exactly is covered under the new criteria, and if any exemptions or waivers exist for commercial/business type ventures. However, the short answer is no. Commercial loan applications are now subject to the same disclosure requirements that...

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The alphabet soup of regulatory agencies (OCC, FRB, FDIC, CFPB, FHFA and NCUA) have issued a set of rule proposals that would apply basic standards for state registration and supervision of appraisal management companies (AMCs).

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All About the Home Owners Protection Act

Posted by Tom April 9, 2014 2:17pm
Sample Image Photo Credit: freedigitalphotos.net

On February 25, 2014, the FDIC has released its revised interagency consumer compliance exam procedures for the mortgage rules that became effective with Dodd-Frank Act. The focus of the issuance of the procedures is part of the FDIC's efforts to inform affected banks about bank regulatory developments in hopes of creating a better dialogue between the FDIC and the institutions it monitors.

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Allowance for Loan Loss Tips and Tricks

Posted by Tom August 7, 2013 2:14pm
Sample Image Photo Credit: David Castillo

A bank’s Allowance for Loan Loss is a perennial hot button issue amongst both state and federal regulatory agencies. It is, without a doubt, one of the most detailed and high risk audits our firm conducts.

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New OCC Guidance Released on Investor Owned Properties

Posted by Tom October 2, 2012 11:07am
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The Office of the Comptroller of Currency (“OCC”) has released new guidelines on credit risk management practices for investor-owned, 1-4 family residential real estate lending where the primary repayment source for the loan is the rental income generated by that property.

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Federal Regulatory Agencies Proposal New Rule

Posted by Tom September 12, 2012 10:19am
Sample Image Photo Credit: dsnews.com

Recently, the six “heavy hitters” of the federal regulatory agencies (i.e., The Federal Reserve, OCC, CFPB, FDIC, FHFA, and NCIA) jointly proposed a new rule to institute additional appraisal requirements for what are defined as "higher-risk mortgage loans." The proposal would enact clauses to the Truth in Lending Act made into law by the sweeping Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

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Strengthening Your Loan Maintenance Monitoring

Posted by Tom September 6, 2012 1:11pm
Sample Image Photo Credit: vichie81

When my team and I visit a client to perform an engagement, there are usually a variety of tasks that we will perform during one audit. Some, such as the Allowance for Loan Loss, are considered high risk by everyone, and taken quite seriously wherever we go. Senior management always looks for feedback or how to strengthen their existing controls.

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New Lending Proposal from CFPB

Posted by Tom August 27, 2012 4:44pm
Sample Image Photo Credit: Stuart Miles

On August 17, 2012, The Consumer Financial Protection Bureau (“CFPB”) proposed new mortgage origination requirements that are designed to bring “greater accountability to the mortgage loan origination market.“

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FDIC Reaches Settlement on Overdraft Fees

Posted by Tom August 21, 2012 1:01pm
Sample Image Photo Credit: David Castillo Dominici

The Federal Deposit Insurance Corporation (“FDIC”) sent out a release on August 8, 2012, stating that it has reached financial settlement terms with a Bank and its affiliate over alleged violations of the Federal Trade Commission Act (“FTC Act”).

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FRB Guidance on Foreclosures

Posted by Tom August 3, 2012 12:13pm
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The Federal Reserve Board recently issued guidance regarding risk management controls and procedures in situations where banks have made a decision not to follow through with foreclosure proceedings after they have been started.

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In the past few months, my team and I have noted an increase in our recommendations to our clients for monitoring and documenting Withdrawn and Denied loans.

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The Summer of CFPB Proposals

Posted by Tom July 11, 2012 11:26am
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The Consumer Financial Protection Bureau ("CFPB") is proposing Consumer Mortgage related changes faster than summer releases at the box office. Here is a summary of the latest that have come down the pipe from on high:

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The Office of the Comptroller of the Currency (“OCC”) has issued an interim final rule amending its lending limit rule to apply to certain credit exposures that were not considered as part of the legal lending calculation previously.

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The ABCs of a TDR

Posted by Tom June 21, 2012 11:11am
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One of the biggest open questions my team sees in the field during our examinations is exactly how to assess our clients’ process for handling Troubled Debt Restructures ("TDR").

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The Supreme Court of the United States issued a rare unanimous ruling May 24, 2012 that resolves early lower court divided decisions, stating that a violation of Section 8(b) of the Real Estate Settlement Procedures Act ("RESPA") happens only when...

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Sample Image Photo Credit: FreeDigitalPhotos.net

On May 9, 2012, Rep. Carolyn Maloney (D-NY), senior member of the House of Financial Services Committee, along with 46 cosponsors, introduced the “Overdraft Protection Act” which would amend the manner in which overdraft fees are collected.

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Our new best friends, The Consumer Financial Protection Bureau (“CFPB”) is preparing to issue rules proposals for loan servicers regarding the criteria and timeliness of the information flow to consumers.

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