Compliance IQ

adjustable rate mortgage

“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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adjustable rate mortgage

“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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adjustable rate mortgage

“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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overdraft image with charts

FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion

The history of overdraft guidance goes back to 2005 with the Joint Guidance on Overdraft Protection Programs. The FDIC followed up with the Overdraft Payment Programs and Consumer Protection Final Overdraft Payment Supervisory Guidance in 2010 and the FDIC Overdraft Payment Program Supervisory Guidance FAQ in 2011. In 2019, the FDIC provided more information relating

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