Compliance

12.23.13

New Documents: RI Financial Institution Insurance Sales Privacy Notices (Cx17887, 17888, & 17889)

This past June, the Rhode Island Department of Business Regulation adopted revisions to R.I. Admin. Code 11-5-99, Sections 5, 7, and 8 of which require certain privacy notices to be provided by licensees under the Banking and Insurance Consumer Protection Act to customers (individuals with an established relationship with the licensee) and consumers (individuals seeking to obtain an insurance product,…

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12.19.13

Updates to Documents: LA Loan Brokerage Agreement and Disclosure Statement (Cx3318)

Cx3318 is provided pursuant to the provisions of La. Rev. Stat. Ann. §§ 9:3572.10 & 9:3527.11 (2013), sections of the Louisiana Consumer Credit Law which require a loan broker to provide to borrowers, in connection with a consumer or federally related mortgage loan,…

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12.17.13

Combining Disclosures Will Simplify Compliance

In efforts to provide borrowers with simpler disclosure documents, the CFPB announced its “Know Before You Owe” disclosure reform rule on Nov. 20. Frederic Gooch, General Counsel and Vice President of Compliance, examines the rule and integration of the two forms,…

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12.13.13

Document Updates: Credit Score Disclosure – B-3/H-3 (Cx15312)

Cx15312 is a duplicate of the Model B-3/H-3 Form provided by the Federal Trade Commission, Federal Reserve Board, and Consumer Financial Protection Bureau pursuant to the provisions of 15 USCA § 1681m(h) (West 2012) and 12 CFR §§ 222.74(d)(1), 1022.74(d)(1),…

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12.12.13

January 2014 New Document: List of Homeownership Counseling Organizations (Cx17874)

12 CFR § 1024.20, which takes effect on January 10, 2014, requires a lender, mortgage broker, or dealer to provide to a loan applicant, within three business days after receipt of a loan application, a list of homeownership counseling organizations which are located closest to the applicant….

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12.10.13

The January 2014 CFPB Regulations – December Update

The following table provides an update of the changes we are making to our documents in order to comply with the forthcoming January 2014 CFPB regulations. Those readers who have not read our previous updates and legal analysis concerning these new regulations are encouraged to view these before reviewing this table (these are available by clicking here for the initial announcements,…

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12.09.13

Documentation in the New World

The sophistication of a lender’s document system is crucial in a heightened regulatory environment. Scott K. Stucky, chief operating officer, examines the critical components of documentation, vendor relationships and data integrity for lenders heading into January 2014 in the September issue of Tomorrow’s Mortgage Executive,…

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12.09.13

Don’t Fear Rate Moves, Be Ready for Possibilities

Market changes will tighten credit options for borrowers, but Scott K. Stucky, chief operating officer, believes that if there is enough loan data integrity, some loan product expansion that’s in line with what the economy can support will open up more opportunities for borrowers….

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12.09.13

Document Changes: Footers of Certain Promissory Notes

In connection with our conventional loans, we provide duplicates of the uniform promissory notes published by the Federal National Mortgage Association (FNMA) on their website (https://www.fanniemae.com/singlefamily/notes). Each of these notes provide a footer stating the name of the document, the form number,…

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12.09.13

Document Changes: Louisiana Mortgage (Cx327) and West Virginia Deed of Trust (Cx359)

The Louisiana Mortgage has been updated to match the most recent model form published by the Federal National Mortgage Association (FNMA). Updates include updated RESPA citations which, while they do not appear on the model form, are authorized by FNMA’s instructions for the new model form….

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