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Save $150 off the individual price of these three webinars!
This six hour webinar recording package features three, two-hour recordings by Jack Holzknecht discussing three timely topics:
- What You Need to Know About Escrows
- Current Status of the ATR/QM Rules
- TRID for Construction Loans
Jack Holzknecht, CEO of Compliance Resource, LLC., is one of the industry’s leading experts in lending regulations. Jack is an experienced presenter and highly skilled in breaking down complex regulation and identify key areas of concern. This bundle saves $150 off the price of these webinar recordings purchased separately.
Program 1: What You Need to Know About Escrows
The Real Estate Settlement Procedures Act (Regulation X) has contained rules for administering escrow accounts for many years. The Truth in Lending Act (Regulation Z) requires escrow accounts in connection with higher-priced mortgage loans. The interagency flood regulations were amended effective October 1, 2015 to add revised escrow rules.
This webinar recording covers all of the escrow rules, including the long standing and the recently revised requirements of the flood regulations, Regulation X and Regulation Z. On May 24, 2018 the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA) became law. Section 108 of that laws amends the Truth in Lending Act and Regulation to provide a new exception to escrow requirements. That section of EGRRCPA was effective on the date of enactment, but regulations from the CFPB are expected. This recording provides comprehensive coverage of the flood regulations, Regulation X and Regulation Z escrow rules. We explain, step-by-step, how to establish, maintain, and cancel escrow accounts under the amended requirements. In addition, suggestions for avoiding violations and penalties are provided.
WHAT YOU WILL LEARN:
- Which loans are required by Regulation Z and the flood regulations to have escrow accounts, and which are exempt;
- The limitations on the amount of the required escrow payments at origination and over the life of the loan;
- How to conduct an escrow analysis;
- How to determine an escrow account computation year;
- The calculation of the amount of the allowed cushion;
- The rules for preparing the initial escrow account disclosure statement;
- The TRID rules regarding the escrow notices required in the Closing Disclosure;
- The expanded Flood Hazard Notice for Escrow information;
- The flood insurance option to escrow notice;
- How to prepare the annual escrow account statement;
- How to resolve a surplus, a deficiency or a shortage;
- Revised Regulation X rules for timely escrow payments and treatment of escrow balances;
- Regulation Z rules regarding escrow cancellation notices;
- The recordkeeping rules for escrow accounts;
- The penalties for the failure to submit an initial or annual escrow account statement; and
- The revisions to the Regulation Z rules made by EGRRCPA.
Program 2: Current Status of the ATR/QM Rules
The Ability to Repay/Qualified Mortgage (ATR/QM) rules were originally released in 2014. The Consumer Financial Protection Bureau (CFPB) revised the rules on September 21, 2015, January 1, 2016, and on April 1, 2016. Now Congress has jumped back in the game.
- Section 101 of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA) creates a new QM standard for small institutions (less than $10 billion in assets) that hold the loans in their portfolio and meet certain other criteria.
- Section 307 of the EGRRCPA orders the CFPB to develop ATR standards for property accessed clean energy (PACE) financing.
The President signed EGRRCPA on May 24, 2018. The provisions mentioned above were effective upon enactment, but the CFPB will revise the ATR/QM rules contain in §1026. 43 of Regulation Z.
So where does this history of change leave your institution?
- Have you evaluated the impact these changes may have on your institution?
- Are the ATR/QM options currently used by your institution still acceptable?
- How do you update your compliance management system to assure the continued success of your ATR/QM compliance program?
WHAT YOU WILL LEARN:
- Which loans are covered by and which loans are exempt from the ATR/QM rules;
- The seven Ability to Repay Options and the five Qualified Mortgage Options;
- What conditions must be met for a loan to be considered under each option;
- When is a transaction considered a Higher Priced Covered Transaction and how that impacts Qualified Mortgage status;
- The options available for lenders using balloon financing;
- What institutions qualify as “small creditors” under the revised rules;
- What special ATR/QM options are available for small creditors, including the option presented by Section 101 of EGRRCPA;
- The expanded definition of “rural area” and how the change impacts your institution;
- How to consider PACE financing when evaluating the ability to repay; and
- What tools are available from the Census Bureau and the CFPB to determine which areas are rural areas and how to use those tools.
Program 3: TRID for Construction Loans
The Truth in Lending Act/Real Estate Settlement Procedures Act Integrated Disclosure (TRID) rules were effective on October 3, 2015. Lenders scrambled to master the details of the new disclosures. Construction loans were particularly difficult because of a lack of binding clarification of the requirements. But help arrived. On July 7, 2017 the Consumer Financial Protection Bureau (CFPB) published final rules to clarify the TRID rules for construction loans. The final rules were effective on October 10, 2017 and compliance was mandatory on October 1, 2018. Finally receiving clarification was a relief but there are a ton of details to master. The CFPB still has not provided sample forms for construction loans, in spite of repeated promises. This two-hour webinar recording presents the details that are essential to mastering compliance with TRID construction loan rules.
The program and the program materials, which are completely updated for the 2018 revisions, provide updated regulatory guidance for construction loans. The program explains coverage and exemption rules and provides section-by-section guidance on completing the Loan Estimate and the Closing Disclosure for the most typical construction loan options. Numerous form samples are provided. The program provides answers for the many questions bankers have regarding the proper disclosure of construction loans.
WHAT YOU WILL LEARN:
- When and why construction loans are covered by the TRID rules;
- How to complete the loan estimate and closing disclosure for:
- Construction only loans
- Combined construction/permanent loans (both one-close and two-close); and
- Permanent financing that replaces construction financing.
- How to properly estimate interest on a construction loan;
- The impact of a construction only loan versus a lot purchase/construction loan;
- When to disclose “Sales Price,” “Estimated Value,” or “Appraised Value;”
- How to determine the proper “Purpose” of the loan;
- How to properly describe the “Product;”
- The proper disclosure of projected payments;
- How to properly disclose inspection fees;
- How to disclose undisbursed construction funds;
- Completing the “Cash to Close”, “Optional Alternative Cash to Close” and “Cash to Close” in the Borrower’s Summary of the Closing Disclosure;
- When the AP Table is needed and how to properly complete it;
- How to complete the “In 5 years” disclosure for short-term construction loans;
- When to include the “60 days prior to consummation” disclosure; and
- Much more.
Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 43 years. In 38 years as a trainer over 145,000 bankers (and many examiners) have participated in Jack’s live seminars and webinars. Jack’s career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by a number of state bankers associations. As a contractor he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.