Other Regulations

The Consumer Financial Protection Bureau, this week, issued Bulletin 2012-02 in response to several inquiries regarding the new Regulation Z rules on loan originator compensation.

The Consumer Financial Protection Bureau published its first semi-annual report to the President and Congress, providing details on the agency’s accomplishments thus far.

NRMLA’s Risk and Compliance Committee has formed two separate task forces to review federal mortgage examination guidelines and identify any potential issues that could adversely impact our members.

A copy of the Consumer Financial Protection Bureau's Mortgage Origination Examination Guidelines is available for download.

The following memorandum written by NRMLA's legal counsel summarizes the CFPB's new exam guidelines and their impact on reverse mortgage lenders.

On October 13, 2011, the Consumer Financial Protection Bureau (CFPB) issued the first edition of its Supervision and Examination Manual (the Manual).

The Consumer Financial Protection Bureau announced this week that former Minnesota attorney general Hubert “Skip” Humphrey will head the new Office of Older Americans, which is conducting a study of reverse mortgages over the coming year.

The Massachusetts Department of Banking adopted numerous recommendations sought by NRMLA prior to publishing a new set of reverse mortgage policies that take effect on October 14.

On September 22, NRMLA submitted comments to the recent "Parity Act" interim final rule issued by the Consumer Financial Protection Bureau.

NRMLA submitted comments to the Massachusetts Division of Banks expressing serious reservations that there will be enough counselors to adequately meet the face-to-face counseling requirement that takes effect next August.

NRMLA submitted comments to federal regulators yesterday seeking an exemption for conventional reverse mortgages that meet the definition of a “qualified residential mortgage” from a proposed Credit Risk Retention Rule.

NRMLA submitted comments to the Federal Reserve Board on July 22 requesting that the Board specifically create alternative criteria for reverse mortgages to meet the definition of a qualified mortgage under its Ability to Repay – Qualified Mortgage Rule.

The FTC issued a comprehensive new advertising and recordkeeping regulation with the potential to greatly affect the mortgage origination and servicing industry, as well as the greater real estate industry that provides complementary services to the mortgage industry.

The White House on Monday nominated Richard Cordray to head the Consumer Financial Protection Bureau. Cordray is Chief of Enforcement at the CFPB.

NRMLA has determined that the model disclosure being developed by the Consumer Financial Protection Bureau should not be used for reverse mortgage transactions and that a reverse-specific disclosure is necessary.

Federal banking regulators are seeking public comments through May 31 on a proposed rule that would prohibit excessive compensation, fees or benefits to be paid to employees, senior executives, directors and primary shareholders, which could lead to inappropriate risks being taken that cause material financial losses to an institution.

The Federal Reserve Board last week announced the imminent publication of a proposed rule that would require sponsors of asset-backed securities (ABS) to retain at least 5 percent of the credit risk of the assets underlying the securities.

NRMLA has submitted a request for clarification to the Federal Reserve Board requesting that it define the “amount of credit extended” on reverse mortgages and suggesting that this should be the "maximum claim amount," rather than "initial principal limit."

On August 16, 2010, the Federal Reserve announced final rules regarding loan originator compensation practices. The following executive summary was written by NRMLA's legal counsel, Weiner Brodsky Sidman Kider, P.C.

The Federal Financial Institutions Examination Council (FFIEC) “pre-published” final guidance today that illustrates for federally regulated institutions the potential risks associated with originating and servicing reverse mortgages – especially proprietary products.

Compliance requirements for reverse mortgages are fast stacking up on lenders as a new set of rules for the product are being embraced by states nationwide.

The American Association of Residential Mortgage Regulators and the Conference of State Bank Supervisors released a comprehensive set of examination guidelines designed specifically for reviewing the business practices and operations of lenders and brokers selling reverse mortgage loans to seniors.

Earlier this week, the Federal Financial Institutions Examination Council announced that it recently updated its "Frequently Asked Questions" on Home Mortgage Disclosure Act reporting as to reverse mortgages.