Law Letters
Read our views on the things that matter to you.
Update on the Registration of Residential Mortgage Loan Originators
The federal agencies (NCUA, Comptroller of the Currency, Federal Reserve System, FDIC, Office of Thrift Supervision and Farm Credit Administration) have announced that the NMLS registration system for residential mortgage loan originators (MLOs) will be...
Upcoming changes concerning Risk-Based Pricing Loans, Transfer of Mortgages and the TIL Disclosure
HAPPY 2011!! This promises to be another great year for residential lenders throughout Texas and we look forward to working with you day-to-day to make this year as productive and successful as it can be! One of the realities facing us in 2011 is a continuing array...
Payment of “Yield Spread Premium” to Mortgage Broker/Originator
The topic of “Yield Spread Premium” has become quite controversial over the past several years and the Federal Reserve (acting to implement the Truth-in-Lending Act and Home Ownership and Equity Protection Act) announced on August 16, 2010 its final rules regarding...
SAFE Act Policies and Procedures
Dear Credit Union Mortgage Lenders: The definition of “Mortgage Loan Originator” in the attached sample SAFE Act Policies and Procedures has been revised to follow the federal SAFE Act definition (rather than the Texas SAFE act definition). Under the federal...
Credit Union Compliance with the SAFE Act
The following information highlights basic Credit Union compliance with the SAFE Act. The NCUA has announced that Credit Unions must adopt a written SAFE Act compliance policy by October 1, 2010. A sample SAFE Act Policies/Procedures is attached to this Law Letter...
Reminder of New Requirements Under Regulation Z for “Higher Priced Loans”
This memo is a reminder to all Residential Mortgage Lenders of Regulation Z’s new requirements for “Higher Priced Loans”. A “Higher Priced Loan” is defined under Reg. Z as “a consumer credit transaction secured by a consumer’s principal dwelling with an annual...
New Changes to Regulation Z
Dear Mortgage Lenders: On Friday, December 5, 2008 the Federal Reserve proposed several very important changes to Regulation Z that if adopted would become effective on July 30, 2009. The period for public comment to the proposed changes ends on January 23, 2009. The...
Fannie Mae Home Valuation Code of Conduct
Effective May 1, 2009, residential mortgage lenders who sell loans to Fannie Mae/Freddie Mac must adopt and comply with the Home Valuation Code of Conduct (HVCC). Lenders who do not sell loans to Fannie Mae/Freddie Mac are not affected by the HVCC. The HVCC is not...
Revised Notice of Servicing Disclosure
Dear Mortgage Lenders, As part of their recent revision of RESPA regulations, HUD has revised the Servicing Disclosure Statement Notice to First Lien Mortgage Loan Applicants, which notice is given to first lien mortgage loan applicants at the time of application or...