“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 3 of a 3 Part Series In our last article we recapped items necessary to comply with the Ability-to-Repay (ATR) and Qualified Mortgage (QM) requirements when underwriting the loan. Compliance with Regulation Z does not stop at origination. This article recaps the servicing requirements for ARM loans. Loan Servicing and The Bank’s Core System
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“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 2 of a 3 Part Series In our last article, TCA recapped items necessary for origination and proper disclosure of ARM Loans. In this second article, we will review the requirements for complying with underwriting requirements unique to Adjustable-Rate Mortgages. Underwriting ARM Loans While banks are required to comply with the Ability-to-Repay standards in
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“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 1 of a 3 Part Series For many years, we have experienced a low interest rate environment and originated predominantly fixed rate mortgages. Well times are changing – with the increase in interest rates, the popularity of Adjustable-Rate Mortgages is gaining momentum. We might be a little “rusty” in the process of originating and
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What is the current status of the sunset of the LIBOR?
Answer: The sunset of the LIBOR has been delayed from December 31, 2021 to June 30, 2023. In spite of the delay, the OCC, The Federal Reserve Board, and the FDIC issued a joint statement that encouraged institutions to cease entering into new contracts that use the USD LIBOR as a reference rate as soon
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HMDA – Field Reporting Exemption under EGRRCPA – When does a Bank Lose this Exemption?
Under the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRPA), many banks were exempt from reporting all fields on the HMDA LAR as they had originated fewer than 500 closed-end HMDA Reportable loans or fewer than 500 open-end HMDA Reportable loans during the prior calendar year. With the dramatic upturn in production during the
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The Great Debate — Is This a Finance Charge?
If only there was a simple answer! Unfortunately, this seemingly simple question can be endlessly debated due to the complexity of Regulation Z. §1026.4(a) states that a finance charge is the cost of consumer credit as a dollar amount. It includes any charge payable directly or indirectly by the consumer and imposed directly or indirectly
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Adverse Action Notice Requirements For Loans and Deposits
When you deny a credit application or a deposit account request, you simply fill out a form and move on to the next customer, right? If only it were that simple! This article will clarify the who, what and why of the different requirements for denying loan applications and deposit requests for consumers and businesses
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LIBOR – CFPB Proposes Amendments to Reg Z to Facilitate Transition
We have all heard that the LIBOR index may no longer be available after 2021 and over the past year TCA has received many questions regarding the transition from the LIBOR. How do we prepare? What is the replacement index? Is there advance notice required? On June 2, 2020, the CFPB released three items related
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