Mortgages Analyzed
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Mortgage Related Laws and Regulations
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The Federal banking agencies issued an advisory to clarify supervisory expectations for using an evaluation for certain real estate-related transactions in response to questions raised during outreach meetings held pursuant to the Economic Growth and Regulatory Paperwork Reduction Act. Many of the questions pertained to when an evaluation is permitted for a real estate-related transaction and how an evaluation can support a market value conclusion when there are few or no recent comparable sales...   Read More
Mar 04, 2016
The FDIC is providing guidance on its initial supervisory expectations in connection with its examinations of financial institutions for compliance with the Truth in Lending Act (TILA) – Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure Rule (TRID Rule), which is effective October 3, 2015.


- If mortgage loans are part of the scope of an FDIC consumer compliance examination, examiners will use interagency examination procedures to evaluate financial instituti...   Read More
Oct 02, 2015
The FDIC has released revised interagency examination procedures for the new Truth in Lending Act (TILA) - Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure Rule (TRID Rule), as well as amendments to other provisions of TILA Regulation Z and RESPA Regulation X. The Consumer Financial Protection Bureau (CFPB) issued a proposal for a TRID Rule effective date of October 3, 2015. The examination procedures should be helpful to financial institutions seeking to better understand the...   Read More
Jun 30, 2015
OCC Bulletin 2015-15
On December 30, 2014, the Office of the Comptroller of the Currency (OCC) published in the Federal Register a revision to its higher-priced mortgage loan (HPML) appraisal rule. The revision adjusts the HPML exemption threshold for smaller loan transactions based on the annual percentage change in a measure of the consumer price index. The rule became effective January 1, 2015.

Beginning January 1, 2015, HPML transactions of $25,500 or less are exempt from the special appraisal requirements co...   Read More
Feb 11, 2015
On January 18, 2013, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Federal Housing Finance Agency, and the Consumer Financial Protection Bureau (CFPB) issued a final rule that establishes new appraisal requirements for higher-priced mortgage loans. Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, mortgage loans are higher priced if th...   Read More
Mar 18, 2013
CA 09-12
This letter provides answers to questions we have frequently received regarding compliance with Regulation Z's repayment ability rule for higher-priced balloon mortgage loans with terms of less than 7 years. In 2008, the Board revised Regulation Z, which implements the Truth in Lending Act and the Home Ownership and Equity Protection Act, to prohibit creditors from making higher-priced mortgage loans 'based on the value of the consumer's collateral without regard to the consumer's repayment abil...   Read More
Nov 09, 2009
CA 09-10
The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council recently approved the attached updated examination procedures for Regulation C (Home Mortgage Disclosure).

The updated procedures incorporate the amendments to Regulation C for reporting pricing information on higher-priced loans as published by the Federal Reserve Board in October 2008 (73 Federal Register 63329). The changes to Regulation C conformed the threshold for rate spread reporting to the...   Read More
Oct 01, 2009
OCC Bulletin 2009-2
On October 20, 2008, the Board of Governors of the Federal Reserve System (Board) approved final amendments to Regulation C (Home Mortgage Disclosure Act) to revise the rules for reporting price information on higher priced mortgage loans. The rules are being conformed to the definition of 'higher-priced mortgage loan' adopted by the Board under Regulation Z (Truth in Lending) in July of 2008. Under the final rule, a lender will report the spread between the loan’s annual percentage rate (AP...   Read More
Jan 05, 2009
The closed-end mortgage provisions of Regulation Z, which implement the Truth in Lending Act and the Home Ownership and Equity Protection Act, have been amended. Among other changes, these provisions now include consumer protections specific to 'higher-priced mortgage loans.' The compilation and reporting of loan data provisions of Regulation C, which implements the Home Mortgage Disclosure Act, now conform to the definition of higher-priced mortgage loans under Regulation Z. The amendments to R...   Read More
Dec 02, 2008


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