Archive

WHAT’S UP WITH FAIR LENDING

There are not a lot of changes with Fair Lending right now, but the topic is red hot. Both HUD and the Department of Justice have taken recent action, and much more is coming. HUD Settlement Agreement On December 21, 2010 the U.S. Department of Housing and Urban Development (HUD), the Metropolitan St. Louis Equal Housing Opportunity Council (EHOC), and First National Bank of St. Louis entered into an agreement that requires the bank to […]

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PENALTY FOR FAILURE TO DELIVER A TIMELY GFE

Apparently examiners have recently slammed a few lenders for the failure deliver a GFE or for the failure to provide the GFE within the required three business day period. The penalty examiners are imposing for this RESPA violation is a refund of all fees imposed in the transaction. Yes; you read that correctly, a refund of all fees. Some bankers are asking what happened to the 10% tolerance applicable to certain items on the GFE. […]

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WHAT’S UP WITH THE DECEMBER 22 REGULATION Z CHANGES

On September 24, 2010 the Federal Reserve board issued an interim rule that requires new rate and payment disclosures in the “Fed Box.” The rule is effective on January 30, 2011. On December 22, 2010 the Fed issued an interim rule that modifies the September 24th interim rule. (An interim rule that modifies an interim rule; the Fed is starting to look like HUD.) The latest interim rule makes a couple of small changes to […]

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WHAT’S UP WITH CRA

It has been years since the federal financial institution regulatory agencies have overhauled the Community Reinvestment Act regulations, but they are working on a total revision right now. And they are constantly tinkering with the rules. The agencies use the CRA regulations to advance social policy. The changes impact how your rating is determined and what activities receive community development credit. Recent Revisions Bankers should view CRA ratings as a game. They need to learn […]

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