Rhode Island Mortgage Bankers Association Joined Habitat for Humanity to Help Build a Lasting Home

PROVIDENCE, R.I. (May 7, 2019) — Mortgage, banking, and finance professionals from Rhode Island Mortgage Bankers Association (RIMBA) rolled up their sleeves to help South County Habitat for Humanity (SCHH) bring a home construction project into its next phase. Volunteers arrived at the site on an early May morning to help two Rhode Island families secure affordable housing at a time when rents in the state continue to rise. Association members and other volunteers surrounded the modest-sized … [Read more...]

Rhode Island Mortgage Bankers Association Advocate for RI Consumers, Lenders During National Conference in DC

PROVIDENCE, R.I. (April 11, 2019) — Mortgage and banking lenders from Rhode Island descended upon Capitol Hill as part of the 2019 National Advocacy Conference. During the two-day event, Patrick Deady, President of the Rhode Island Mortgage Bankers Association (RIMBA), met with Sen. Jack Reed and staff from Rhode Island’s congressional delegation to advocate on behalf of consumers and mortgage professionals in Rhode Island. “A stable real estate economy is essential to maintaining the … [Read more...]

HMDA Reporting on Construction Loans

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. When is Financing “Temporary?” Today I want to take a look at one of the least understood topics in HMDA—temporary financing exemptions. These exemptions most often come up in the context of construction loans (read: commercial loan dept); but the classic “bridge loan” scenario we often see on consumer residential transactions is also captured under the 12 C.F.R. 1003.3(c). Statutory Language The language of the “Temporary … [Read more...]

Vendor Management Best Practices

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. When regulatory requirements impact strategic or management action, our goal is to help business leaders make well-informed decisions. Outsourcing a function DOES NOT outsource the corresponding Risk "Reliance on third-party relationships can significantly increase a bank's risk profile, notably strategic, reputation, compliance, and transaction risks. Increased risk most often arises from poor planning, oversight, and control on … [Read more...]

How Are You Keeping Up With Regulatory Changes?

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. When regulatory requirements impact strategic or management action, our goal is to help business leaders make well-informed decisions. With the CFPB, the Only Certainty is Change At this point, we’ve seen so many “will they or won’t they” moments for the 2018 (and beyond) HDMA rule that the CFPB should hire Brett Favre as the official HMDA spokesman. In just the last 30 days, we’ve seen multiple legislative and … [Read more...]

Some Thoughts on Compliance Training

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. Habits that served us well in the past may hurt us after regulatory change. Getting HMDA Wrong? It’s All About the Habits …  Experience is typically viewed as a positive trait, particularly in highly repetitive operations such as mortgage originations. So much so that I’ve always viewed my lack of “Old HMDA” experience as a glaring hole in my knowledge. Those who have reported HMDA transactions for years often know their … [Read more...]

Successors in Interest Under the 2016 Mortgage Servicing Rule

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. Are your policies and procedures ready for the successor in interest rules?  The 2016 Mortgage Servicing Rule, which amends parts of Regs X and Z, creates certain rights for "successors in interest" to the borrower in a mortgage lending transaction. Although most of the 2016 rules have already been implemented, the effective date of these successor in interest provisions is April 19, 2018. Depending on whether you meet certain … [Read more...]

HMDA “Loans in Limbo”: 2017-2018 Timing Issue

Article By: Ben Giumarra, Spillane Consulting Associates, Inc. Remember this later with that 2017-18 reporting window, but also understand now if you're thinking strategically about HMDA 2018. We know that January 1, 2018 is the date new HMDA data collection rules kick in. But what exactly do we do with "loans in limbo" - loans where we take an application in 2017 but don't take final action until 2018?   Side note: I bet a lot of people are going to have this question, but only for … [Read more...]

Should You Delay Appraisal Delivery Until After Review?

Article By: Ben Giumarra, Spillane Consulting Associates, Inc. A common grip from borrowers - could compliance concerns be getting in the way unnecessarily? Sick of borrowers complaining "Where is my appraisal? The appraiser was here  a month ago!" Well, you're not alone. Especially for refinances in markets where housing prices are fluctuating, this can be one of the most anxious parts of the mortgage process for a borrower. What's my house worth? Is it going to be enough?    Often, … [Read more...]

HMDA Exemptions for Commercial Loans

Article By: Ben Giumarra, Spillane Consulting Associates, Inc. Let's build off of last week's newsletter and discuss the significance of identifying a loan as business-purpose. So last week we discussed how the new HMDA rules require us to report whether every single loan is "business-purpose" (thus exempt from Regulation Z) or "consumer-purpose." This is one of a couple of ways for a loan to be exempt from Reg Z. Exemptions for Business-Purpose Loans I wanted to provide a convenient … [Read more...]