Recently I taught on the topics of HMDA & Flood Insurance at the ABA’s Compliance School in San Jose, CA (it’s a tough job, but someone has to do it).
HMDA – Jane Gell (FRB Managing Counsel) indicated the FRB is considering adding 12 items to the LAR: FICO Score, APR, Debt to Income, Loan to Value, etc. The OCC has been testing “HMDA Plus” for the past couple of years & the FRB appears to like the results. Before you groan too much, I think this is beneficial for you. Currently, the HMDA data may make it look like your institution is discriminating against a protected class. This new data will help you defend your actions (“yes we have denied _____ more, but look at their FICO scores, DTI ratio and LTVs on these applicants.”)
Truth in Lending – Refinance vs. Renewal: Currently, Reg Z (as well as RESPA) allows you to avoid giving new disclosures when you renew a note rather than refinance it [refer to 226.20(a)]. The FRB is looking at changing the rules especially considering the “legal circumvention” this allows to avoid new requirements like Higher Priced Mortgage Loan requirements.
RESPA – Lucy Griffin (Consultant) taught this course and had the following notable comments:
Published
2010/04/27
David Dickinson