CoAMP News

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  • 21 Nov 2013 11:17 AM | Anonymous

    DORA

    For those of you who didn't know, I visited DORA yesterday in Denver for the Board of Mortgage Loan Originators Meeting.  It was an interesting morning to say the least.  They are still actively dealing with licensing issues, marketing issues and rule changes.  They discussed license requirements, continuing education, renewal procedures, rules that are going to be cleaned up and current investigations.  Their next meeting will be January 15, 2014 at 9:00am.

    CO Housing Council

    After the DORA meeting, I made my way to the University Club to have lunch with the CHC group.  The presenter was Ron Milzer with MDC Holdings (Richmond Homes).  He went through some really good data during our time there.  In short, I came away with these bullet points:

    Denver and CO in general is a very stable market

    Builder contracts are up +20% YTD

    Builder Sales Contracts dropped like a rock when Bernanke announced "tapering", they have not bounced back

    3rd Quarter is generally weak for housing starts, but has had its best quarter since 2007 this year

    All Housing Sales are up +21% but inventory is VERY limited, only 2.3 month's supply in Denver (their lowest since 2000)

    The last time the supply of 'resale' inventory was less than 3 months Denver experienced double-digit appreciation...

    This year Denver has experienced its highest annual appreciation in home values since 2001

    Public Trustee Deeds & Election & Demands are at their lowest points since before the real estate crash

    Land is very hard to find for builders.  

    Land that is already developed is nearly non-existent.

    Notice of Defaults spiked in September to over triple the previous month and the highest point in 2 years

    New home median prices have seen roughly 35% appreciation since 2010

    Foreclosures are at their lowest levels in 10 years

    Vacancy rates have followed a similar path

    Rent rates are on the climb

    Cordray unveils ‘Know Before You Owe’ mortgage rule

    The head of the Consumer Financial Protection Bureau announced a new rule to simplify mortgage forms Wednesday – but some industry groups are calling it an undue burden on smaller lenders.

    Speaking at an event in Boston, CFPB Director Richard Cordray laid out the “Know Before You Owe” mortgage rule, which will require lenders to provide simplified mortgage forms that will make it easier for the borrower to find information like interest rates, closing costs and monthly payments. The rule is scheduled to take effect in August of 2015.

    For full details, visit:

    http://www.consumerfinance.gov/knowbeforeyouowe/

  • 05 Nov 2013 10:35 AM | Anonymous
    http://www.namb.org/namb/GA_Home.asp?SnID=1449768433

    From NAMB site:

    I am pleased to report that YOUR participation in helping NAMB collect data about consumer credits and the impact the QM's 3% point and fees cap has really turned some heads in D.C.

     

    NAMB, along with other trade groups such as MBA and NAR have been invited to meet with Director Cordray and his staff on to discuss the impact of the points and fees cap, the disparities against mortgage brokers, and the ability for consumers to truly shop and compare mortgage loans.

     

    Our efforts, along with your support, really do go a long way. We may not always make our efforts public, but understand that we have our industry's best interest as well as that of the consumer at heart. For example, we met with the CFPB two months ago to discuss consumer credits, our efforts were picked up and reported positively by the main street press, and here we are with an invite from Director Cordray himself. 

     

    NAMB does have open lines of communication with our regulators and we will continue to work with them to improve the state of housing and do what is best for the consumer. 

  • 10 Sep 2013 1:30 PM | Anonymous
    Agenda
    9/18/13
    9:00 am
    1560 Broadway Ste 1250-C
    Denver, CO 80202

  • 10 Sep 2013 1:06 PM | Anonymous
    Topics:
    Liability
    General ATR Standard
    General QM Definition
    Other QM Categories
    Points & Fees
    Exemptions for Certain Creditors & Lending Programs
    Further CFPB Amendments Pending
    QM Compliance & Fair Lending
    CFPB Not Budging on January Effective Date

  • 31 Mar 2013 10:58 AM | Anonymous

    As President of CoAMP, I attended the NAMB Legislative Conference in D.C. on 3/10-3/12/13.

    Below are key Compliance Tips in case of CFPB audit

    Broker Owners:

                NMLS Call Reports: Did you know your Tangible Net Worth requirements must be met consistently and not just once a year? NMLS resource center will help clarify requirements: http://mortgage.nationwidelicensingsystem.org/slr/common/fs/Documents/FS%20Table.pdf

    This will be looked at closely to ensure timely reposting and accuracy of information.

                Policies and Procedures: Have updated and clean manual in your office that is pertinent to your business model. Keep full documentation of training of your LO’s and staff to ensure all are following your Policies and Procedures.

                Documentation: in conjunction with your NMLS Call Reports be sure to have a very detailed list of all loan transactions to help identify patterns for possible disparate impact. When in question contact the CFPB for assistance (855) 411-2372 or http://www.consumerfinance.gov/askcfpb/submit-question and document your initiative and their response.

                    Compensation: if you have different LO Comp % with multiple lenders and/or pay your LO’s different %, be sure to have the reasons documented well as to why you made these decisions.

    Following the Rules:

                    State law trumps Federal law in regard to policies, disclosures, guides. If a lender asks for something which is in conflict with State requirements, contact your state regulator for guidance.

                    Processors who are ‘in-house’ and not licensed, be very careful they are not “arranging a transaction” with borrowers and not discussing any loan options and/or details of the transaction. This will be looked at carefully to ensure processors are not operating as an Originator is they are not licensed.

                    Licensing will be audited. If an LO is not licensed in another state and submit an application under the license of another LO who is, this will be discovered very easily and is a hot-spot for CFPB.

                    Advertising rules for your state will be monitored very closely especially social media, so contact your state regulatory office to ensure you are following protocol. www.colorado.gov (303) 894-2166.

    LO Comp Rule effective 1/10/14:

                    New rule will remove the dual comp issue for borrower-paid transactions and allow broker owners to pay LO’s per transaction and not require the hourly/salary compensation. LO’s will be able to be paid in the same manner as lender-paid compensation

                    LO’s on a borrower-paid will be allowed to cover unexpected costs for borrowers. These must be UNEXPECTED costs, i.e. originally had a PIW option and now full appraisal is required, so LO may pick up the cost for borrower. be sure these are well documented instances.

    Qualified Mortgage/Ability to Repay Rule effective 1/10/14:

                Lenders will have ability to choose to provide QM/ATR mortgage or not. If a lender provides a non-QM mortgage, this will allow borrowers who default to have ability to pursue TILA damages against the lender. Currently, QM will tighten DTI limits to 43% back-end ratios (non-government loans) and also cap all fees and point to under 3%. The 3% cap will include lender fees and LO Comp. NAMB’s HR 1077 is currently working to amend the calculation of fees as there are several issues pointed below, which is what I was discussing with our Congressmen in D.C.

    1.      On Lender-Paid transactions the LO Comp is being “double-dipped” by counting the company compensation and then the compensation to originator again. NAMB/CoAMP suggest a revision to the Rule to only count the compensation going to the originator.

    2.      Lender underwriting fees will be included in the 3% and this may mean that lenders will remove the upfront fee and build it into rate/price, which will result in higher rates for consumers.

    3.      Since the 3% is based on the loan amount, this may cause disparate impact issues for lower loan amount borrowers.

    4.      This Rule will only affect wholesale brokers and thus will put small business at a competitive disadvantage and reduce consumer lending options

    CFPB: Consumer Financial Protection Bureau

                They are responsible for enforcement and clarity on Dodd-Frank regulations. www.consumerfinance.gov and welcome comments from industry professionals as well as consumers at https://help.consumerfinance.gov/app/tellyourstory

    Adrienne L. Randol, CML 

    2013 President of CoAMP (Colorado Association of Mortgage Professionals)

    303-720-9450 arandol@franklinamerican.com

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