Article by: Ben Giumarra, Spillane Consulting Associates, Inc Could you gain some efficiencies with how your making certain Flood disclosures? Let's discuss what's required (and not). So today we continue our war against disclosure packages bogged down with unnecessary stuff. One page, sometimes one sentence, at a time. It might not seem like a lot - but #1) removing one disclosure might remove 2 hours of back-and-forth with a borrower getting an unnecessary signature, and … [Read more...]
Lender’s Obligation for Seller’s Closing Disclosure?
Article by: Ben Giumarra, Spillane Consulting Associates, Inc You're checking (and re-checking) your Closing Disclosures to avoid any errors and to fix any that do occur post-closing. They're finally looking a lot better, but you're now seeing plenty of problems with Seller CDs, which are provided directly by closing agents. Do we worry about this or not? Let's talk this through now so you can have an intelligent and confident conversation with regulators if this ever comes up in an exam, … [Read more...]
Unnecessary Disclosures: Servicing/Rescission – CFPB Death Penalty?
Article by: Ben Giumarra, Spillane Consulting Associates A couple of forms you might not need anymore. Plus a note on one mortgage lender's death penalty from a CFPB enforcement action. Here at SCA we've been fighting a war to help shrink, update, and simplify loan files. This is a war where battles are fought one page, sometimes one sentence, at a time. Bloated loan files decrease borrower satisfaction and increase uncertainty (sometimes confusing ourselves). The good … [Read more...]
Simplified HMDA Data When Applicant Declines to Report GMI
We in the regulation, I mean mortgage, industry are all teaching ourselves about the new HMDA requirements. One particular issue that may catch your attention is the more nuanced demographic information to be collected, and how to get that right - especially when based only on visual observation. I'm guessing this will be a big training topic this year. So let's break it down! "Disaggregated" Data Soon HMDA will require us to collect "disaggregated" demographic information. … [Read more...]
TRID Tips on Speeding-Up Closing
TRID Tips on Speeding-Up Closing Who has time to waste? Take Alec Baldwin's advice from Glengarry Glen Ross and "Always Be Closing" Mistakes happen when you're rushing through a stressful or complicated scenario. Just ask the bank robber who used a personal check as a robbery note (yes, they caught him almost immediately). But speed is essential to a successful mortgage operation. With that in mind, here are some ideas for safely speeding up your … [Read more...]
Understand which vendors need extreme vetting per CFPB
Which vendors require due diligence, written contracts, and all the rest? CFPB-regulated institutions are required "to have an effective process for managing the risks of service provider relationships." See CFPB Bulletin 2016-02. I know, I know, you're thinking Cash me ousside, howbow dah? - but let's be reasonable.As we depend heavily on 3rd parties, it's important to understand who falls under this umbrella: settlement agents? LOS providers? call centers? VOE … [Read more...]
Dodging HMDA-applicability on pre-approvals under the new rules
Dodging HMDA-applicability on pre-approvals under the new rules It's nice to avoid HMDA reporting requirements when you can, for example by using pre-qualifications instead of full pre-approvals. But how exactly can you do this when the new rules take effect? As my colleague Tom pointed out Monday morning, productivity for this week in New England suffered a blow on Sunday night. But … [Read more...]
Golf Tournaments Raises Funds and Awareness for the American Cancer Society
Rumford, Rhode Island; August 2015 – The Rhode Island Mortgage Bankers Association (RIMBA) annual golf tournament to raise funds and awareness for the American Cancer Society was a huge success for the 20th year in a row. Held at the picturesque Agawam Hunt private club which marked its official beginning in 1897, the golf tournament took place on August 18 and raised over $1,100 for the American Cancer Society in the name of Patti Slepkow. Patricia (Patti) K. Slepkow of Steamboat Springs … [Read more...]
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