Article By: Ben Giumarra, Spillane Consulting Associates, Inc. You ask, we answer.  Question A friend of mine sent me this compliance question a while ago:   What happens when an loan originator's NMLS number is valid at time of application, but becomes invalid for a period of time, possibly being reinstated by- or after closing? Our system is reporting this as a compliance error. We have an originator that allowed their NMLS license to lapse, so there will be a couple of days … [Read more...]

Article by: Ben Giumarra, Spillane Consulting Associates, Inc. Two weeks ago we proposed a quiz to use related to the 560-page July TRID Rule update. Last week we provided the (our) answers to the first half of the quiz. This week includes the final half.  Last week we completed the first half of the questions. This week we "bring it home" with the final questions to the TRID quiz.  If you recall, the TRID quiz was a test to see how well someone knew the 2017 TRID Rule. TRID Quiz: July … [Read more...]

Article by: Ben Giumarra, Spillane Consulting Associates, Inc. Last week we proposed a quiz to use related to the 560-page July TRID Rule update. How did you and your team do? Do you agree with all of my answers here?  Okay, let's see how you (and I) did! TRID Quiz: July 2017 Updates Remember the instructions: Using the heading/topic below only, explain in a sentence or two the applicable part of the July 2017 Rule (which you can read here - and if 560 pages is too much for you, … [Read more...]

Article by: Ben Giumarra, Spillane Consulting Associates, Inc. Quiz your team on the most recent TRID update. If the definition of "loan originator" is broader under TILA than under the SAFE Act (which it is), why do so many institutions have more NMLS-licensed employees than true originators (who are subjected to TILA qualification, compensation, and training requirements?). The most recent TRID update was finalized last Friday. The mandatory compliance deadline is October 1, 2018. At … [Read more...]

Article By: Ben Giumarra, Spillane Consulting Associates, Inc. Trying to do the right thing might make things worse here.  If the definition of "loan originator" is broader under TILA than under the SAFE Act (which it is), why do so many institutions have more NMLS-licensed employees than true originators (who are subjected to TILA qualification, compensation, and training requirements?) Short Answer Well, they shouldn't. If you have more people with NMLS licenses than who … [Read more...]

Article by: Ben Giumarra, Spillane Consulting Associates, Inc. So maybe a bit of a "clickbait" headline, but what's stopping your institution from having a mortgage originator who has a second job? What's stopping a mortgage lender from having part-time MLOs?  The appeal of working as an Uber (or Lyft) driver is that it can be a "side hustle" - a job you work in addition to your regular job for extra money. You can earn some extra money working whenever/wherever you decide. With the … [Read more...]

Article by: Ben Giumarra, Spillane Consulting Associates, Inc. Special two-part series this week! First a quick note on HMDA and corrected disclosures. Second, some takeaways from a recent Federal Reserve publication on finance charges.    Part 1: HMDA with TRID Changes One consideration with the new HMDA rules will be going back and updating the LAR when corrected disclosures are provided. This is a bigger issue than years before for two reasons: (1) There is more data to … [Read more...]

Article By: Ben Giumarra, Spillane Consulting Associates, Inc. Regulations are often blamed for stifling innovation - how many new and unique loan products have we seen lately? You see similar hesitation on new internal processes. Is Day 1 Certainty destined for the same fate? I think No. Are you staying "up with" Day 1 Certainty changes? 9 out of 10 lenders are not. But the 10th lender will sound like a mad scientist when you ask them about it. It's an interesting knowledge gap right … [Read more...]

Article by: Ben Giumarra, Spillane Associates, Inc. A significant shift in policy that you should be aware of if your institution is subject to Consumer Reinvestment Act requirements. Mortgage companies skip to the cartoon! How do you draw an Assessment Area? Various factors should shape your Assessment Area - but two in particular are being given greater importance: the existence of County lines and Low-to-Moderate Income geographies. Don't get caught off guard in your next CRA … [Read more...]

Article By: Ben Giumarra, Spillane Consulting Associates, Inc. Getting some attention because of Fannie Mae's HomeReady and other innovative programs, this an interesting question to review. "Shadow rent" is non-borrower household income that can be contributed to the monthly housing payments. Earning $60,000 per year, single mom Bristol has a monthly mortgage payment of $2,000, recurring debts of $400, and thus a debt-to-income ratio of 48%. Not good. But what if her elderly father lives … [Read more...]