Feb. 14, 2013 – NAFCU webcast participants yesterday gained valuable insight about seven new CFPB regulations that will impact credit union mortgage lending, including the scope of the requirements and what steps need to be taken to comply with them.
The webcast, “The CFPB’s Final Mortgage Regulations,” featured NAFCU Director of Regulatory Compliance Steve Van Beek and was moderated by NAFCU General Counsel and Vice President of Regulatory Affairs Carrie Hunt. It gave participants an overview of the CFPB’s requirements relating to escrows for higher-priced mortgage loans; loan originator compensation; mortgage servicing (Reg Z and Reg X); qualified mortgage/ability-to-repay; high-cost mortgages; appraisals for high-priced mortgage loans; and appraisal disclosure and delivery. Together, the requirements account for 3,507 pages of explanatory text, regulations and interpretations, Van Beek said.
In discussing the thresholds and requirements for higher-priced and high-cost mortgage loans, Van Beek noted key differences. While both sets of requirements use an annual percentage rate compared against an average prime offer rate, the scopes of the rules differ, he said. A home equity line of credit, for example, could be a high-cost mortgage but not a higher-priced mortgage since the latter is limited to closed-end credit. The APR thresholds also differ, he said.
Van Beek also paid special attention to the small servicer exemption for the CFPB’s mortgage servicing requirements by explaining which requirements exempt small servicers. He also noted which mortgage loans credit unions must count when determining their eligibility for the 5000 transaction exemption threshold.
The webcast provided participants a list of effective dates of the new rules and NAFCU-created downloadable charts that help credit unions analyze the new requirements and determine their scope.
Wednesday’s webcast is the first in a new series NAFCU is doing on CFPB mortgage rules. The webcast is available on demand for view by participants and is also available for purchase for those who missed it.
Registration is now open for the second, third and fourth webcasts in the series.