Over the last few months, Fannie, Freddie, FHA, VA and USDA have not issued any underwriting rule updates—which is a good thing. But it’s been replaced with the Consumer Financial Protection Bureau constantly tweaking the rules.
Before we get to the CFPB tweaks, let’s start with the social media guidelines from the FFIEC, who normally regulate the banking industry. But since that agency is now under the CFPB’s umbrella, their guidelines now apply to mortgage companies too.
The guide is 36 pages long, but essentially what it means is that if you post anything onlinetexts, emails, blogs, social media page, websites, forums, photo sharing, things like thatthere is a policy in place to make sure nothing violates any of the regulations.
For example, if you post an interest rate on your Facebook page, the entire disclosure must also show up there−including the APR, the terms and the type of loan. If you quote a payment, same thing, and in addition you must state whether that payment includes taxes and insurance.
The article lists 18 different regulations/agencies which will be monitoring your social media info.
While this is supposed to be part of your company’s policy and procedure manuals, it will ultimately come down to you and what you say online that could get your company in big trouble.
Next, FHA has issued a mortgagee letter reminding lenders of the Good Neighbor Next Door program.
Just a recap of what the program is all about:
It’s available to firemen, law enforcement and teachers.
They can purchase a HUD home or a home located in a revitalization area for 50% of the listing price.
They must live in the home for 36 months.
HUD gives them a second mortgage for the 50% balance. If they live in the home for 36 months, the second mortgage is forgiven. Plus, the mortgage insurance is only charged on the first mortgage.
Here’s what’s new: If for some reason the buyer has to move out of the home for a short period of time (and is planning to move back at a later date), HUD will now allow them to request a “waiver” for the interrupted time and extend the 36-month time period.
NMLS has updated their website with 25 pages of new regulations—but only a handful applies to you. What they have done is hired a third party company to post all of your course and education records in one location—basically a snapshot of all employees’ education. Consumers will also be able to see what courses you have taken.
And, here are just a few important updates from CFPB.
The new Adverse Action and Right to Receive Appraisal Forms will be going into effect on Jan, 18, 2014. Check with your LOS vendor to make sure they are updating their system as well.
Next, this one is basically for managers—the CFPB has also issued a bulletin with an outline on how to monitor employees and lending activity within your company. In other words, they expect companies to “police” themselves and provided a guide on how to do that.
It’s kind of a double-edged sword—it could get you in hot water or it could be your saving grace. I’ve have created a checklist (that www.MortgageCurrentcy.com subscribers can download) for company owners with the questions that CFPB suggested that you review with everyone on your staff so they know what to look for when it comes to fraud, anti-money laundering and agency regulation violations.
Oh, and they are also into videos these days—posting a series of them called “Mortgage Rules at a Glance.” They are between 15 to 20 minutes long. Here’s the link to view them:
Thanks for reading this short synopsis, and remember that getting a loan approved and closed these days IS ROCKET SCIENCE.
