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December 19, 2017

We are just a few short days away from the new HMDA rule implementation. What last minute details are your peers concerned most about? Why are people revisiting their existing HMDA data collection procedures? Listen in as I discuss with resident HMDA expert Melissa Kozicki!

 

 

December 12, 2017

Although we're just days away from the HMDA rule's January 1 effective date, there have been rumblings that the CFPB might be inclined to either delay or announce a one-year voluntary compliance period. A last-minute announcement is a real possibility, for which you should be prepared. What's your plan to deal with it?

 

November 14, 2017

Listen in as we continue our discussion with Jerra about the cross-qualification problem. In our last podcast, we learned about the cross-qual conundrum. Now, you'll learn how to educate your LOs about the right way to handle them.

 

November 7, 2017

Cross-Qualification = when the listing agent demands that your loan officer send a borrower's personal financial information, credit report and/or AUS findings to a competing lender prior to submitting an offer...or something like that.

Just so you know, the practice may violate GLBA and the lender's own privacy policy. It may violate the lender's contracts with the GSEs. It is also very likely that an underwriting decision is taking place, invoking disclosure requirements that aren't being complied with under TRID, TILA, RESPA, required reporting that isn't taking place under HMDA and treatment/disclosures not happening under ECOA if the loan is not approved. And we haven't even touch...

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roger@fendelmanconsulting.com

636.399.0169

 

The information contained herein is opinion only and is not, nor should it be construed as, legal advice. No attorney-client relationship exists. This is not attorney advertising and is not a solicitation for legal services.

© 2017 Roger Fendelman. All rights reserved. "Bridging the Gap Between Compliance and Technology" and "Compliance Insiders" are service marks of Roger Fendelman.