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ANOTHER Late Breaking Development! The CFPB has been busy! On July 2, 2020 they issued another Notice of Proposed Rulemaking to implement Section 108 of EGRRCPA – to create a new replacement exemption from the mandatory escrow account requirement for HPMLs. This rulemaking guidance has been long awaited since 2018, and will change who (looking at YOU, small creditor!) can take advantage of the exemption. The good news: The Small Creditor asset threshold is increasing from $2B to $10B… the bad news (maybe): the Small Creditor loan volume size is decreasing from 2,000 to 1,000 loans/year – but the type of loans to be counted is changing too.
Confused? Tune in to this webinar on July 20 to find out all about the new exemption before the short comment period (just 60 days after Federal Register publication) expires.
There are a lot of moving parts to all of this! Attend the webinar to make sure you have it all straight!
Late Breaking Development! On June 22 the CFPB issued a Notice of Proposed Rulemaking to amend the ATR-QM rule in two ways: 1) extend the Temporary GSE QM sunset to a later date; and 2) significantly change the General QM definition – we’re talking an elimination of BOTH the 43% DTI requirement and use of Appendix Q! These requirements would be replaced solely by new APR/APOR rate spread requirements… unless proposed alternative approaches are adopted by the Agency. Say what???
The comment period is short – 30 days (after Federal Register publication) for the Temporary GSE proposal and 60 days for the General QM proposed changes. Educate yourself by attending this webinar on August 5 to fully understand the proposed changes in time to comment on the General QM revisions, and how they fit into the bigger QMATR / HPML picture!
If you feel a bit rusty or confused about these numerous perplexing rules, this webinar is for you!
As much as regulators like vanilla loans, the needs of homeowners aren’t that simple. Thankfully, community banks have unique options available to them as they make dwelling-secured loans to their customers. From Small Creditor QM loans, to Balloon QMs, to the new S2155 EGRRCPA allowance, to plain ATR loans, the route to take can be daunting and confusing. Add to that HPML requirements (if the loan ends up being a Higher Priced Mortgage Loan) and the resulting stew of regulation is enough to make any banker run from the proverbial hot kitchen!
The fact that the rules have been around for a few years now has not made them any easier. If anything, the passage of time has largely worked to muddle and blur what was once a sharper understanding of the essentials. Changes to the existing rules have contributed to the cloudiness.
Join this webinar to bring clarity, a renewed understanding, and a fresh perspective to the rules. The ultimate goal of this training is to ensure your bank is not only complying with the regulations but also taking every opportunity available to compete and serve your communities. Don’t fall into the trap of “we’ve always done it that way”, but rather take some time to analyze why and how you make dwelling secured loans.
This webinar will go over the foundational requirements for QM and ATR underwriting, delve into small creditor and rural & underserved creditor relationships, and explore how the requirements impact:
- Higher Priced Mortgage Loans (HPMLs);
- Higher-Priced Covered Transactions (HPCTs);
- High Cost Mortgage Loans (HCMLs)
In addition to the webinar slides and a regulatory manual, participants (you!) will receive helpful reference sheets and tools to help maximize comprehension and your ability to convey understanding to the people in your institutions. This is crucial! Not only do you need to have a strong grasp of the requirements, but you need to be able to communicate them to your decision-makers and staff. Everyone will comply better if they have a better understanding of the rule’s goals and objectives. Blind compliance is always more difficult, so educating yourself and others will benefit everyone.
Upon completion of this two hour webinar participants will:
- Get a succinct review and update on HPML requirements;
- Receive insight on the biggest “gotcha” that trips up banks making HPMLs;
- Comprehend the critical interplay between HPMLs and QMATR;
- Discover when, why, and how bankers can make non-QM HPMLs;
- Consider the unique issues surrounding manufactured home lending;
- Gain clear insight on compliant QM underwriting, including the types of QMs available to you;
- Explore EGRRCPA’s additional QM relief;
- Take a fresh look at ATR underwriting and when this baseline method can be used all on its own;
- Ponder the application of the rules to investment properties;
- Uncover what being a “Small Creditor” really does (and does not) do for you;
- Understand what it means to be a “Rural / Underserved” lender;
- Receive webinar slides and a manual with helpful tools and reference sheets
EGRRCPA 101 Revisions
Section 32 High Cost Mortgage
Section 35 HPML Info Sheet
Questions and Answers