IMA Prime Times e-Newsletter: September 2017 Iowa Mortgage Association

September 2017


President's Message

Association Updates
Industry News


It’s been a great year!
It is truly a privilege to be connected with the Iowa Mortgage Association (IMA). There are so many colleagues that I have met who I now call friends. 

It has been another great year to be in the mortgage industry. Rates have stayed low and there have been many buyers needing assistance.

Thanks to all of you for your support this past year as I served as your Iowa Mortgage Association (IMA) President. I will be handing off the reins to Marcy Wagner from Titlecore National, LLC as the incoming president for 2018.

I hope to see you at the Fall Conference in just a few short weeks; please invite a friend to attend with you!

Vicki Davis
Central Bank


Still time to register for IMA Fall Conference and golf outing
The Iowa Mortgage Association (IMA) Fall Conference is coming in October, and there’s still time to sign up. The conference will kick off with a golf outing on Oct. 2, and the conference will be Oct. 3-4 at the West Des Moines Marriott Hotel. This year’s event is designed to help mortgage lenders become more knowledgeable about the industry and increase their awareness about today’s top issues. The convention is a must for any mortgage professional. The cost for registration is $225 for members if signed up before Sept. 26. After that date, the cost increases to $245. The cost for nonmembers is $450. Click here to learn more or to register for the convention. 


HMDA rule changes finalized
With the implementation date a mere four months away, the Consumer Financial Protection Bureau (CFPB) issued a final rule on Aug. 24 changing various provisions of Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). In addition to the final rule, the CFPB issued an executive summary, which provides an overview of the changes. The CFPB indicates its amendments make technical corrections and add clarification to the existing provisions, making only limited changes to certain requirements. With the release of this final rule, a delay in the Jan. 1, 2018, implementation date seems unlikely.

HMDA resubmission guidelines revised
The Federal Financial Institutions Examination Council (FFIEC) member banking agencies have issued revised guidelines for how examiners will test the accuracy of data collected and reported by financial institutions under the Home Mortgage Disclosure Act (HMDA). The resubmission guidelines can be found here.

Despite concerns expressed by current HMDA reporters and industry participants about the burdens imposed by unreasonable error tolerances that require a bank to resubmit its HMDA data and requests for more reasonable tolerance standards, the new guidelines are expected to have the opposite result, creating disproportionate expectations for smaller volume lenders. For example, an examiner will review 30 loan files of a bank that only makes 50 mortgage loans but only 159 files for a bank that originates 100,000 loans. Moreover, a small number of errors in any given data field will trigger review as resubmission is required for a bank submitting a LAR with 500 lines or less with a threshold of three errors in any one data field. 

CFPB announces new 'reg inquiries' web tool
The Consumer Financial Protection Bureau (CFPB) announced the launch of a new web form to replace the email address (CFPB_RegInquiries the industry and other stakeholders use to submit their questions on CFPB regulations. The form can be found on the CFPB website and requires those submitting questions to select the regulation and regulatory section to which their question pertains.

FDIC updates affordable housing guide
The FDIC has updated its Affordable Mortgage Lending Guide. The guide provides information to help make bankers aware of the wide range of current affordable mortgage products available. It is part two of a three-part series covering federal, state and FHLB affordable housing support. Changes to the newest version include product and program updates from state agencies, the addition of a new program and the addition of alternative private mortgage insurance options. The guide can be found on the FDIC website.

CFPB sets 2018 Reg. Z thresholds 
The Consumer Financial Protection Bureau (CFPB) issued a final rule in the August 30, 2017 Federal Register amending the official interpretations for Regulation Z, which implements the Truth in Lending Act (TILA). The Bureau is required to calculate annually the dollar amounts for several provisions in Regulation Z. The adjustments are based on the annual percentage change reflected in the Consumer Price Index (CPI) in effect on June 1, 2017. The applicable dollar threshold amounts are effective Jan. 1, 2018. For Home Ownership and Equity Protection Act (HOEPA) loans, the adjusted total loan amount threshold for high-cost mortgages in 2018 will be $21,032. The adjusted points and fees dollar trigger for high-cost mortgages in 2018 will be $1,052. For the general rule to determine consumers' ability to repay mortgage loans, the maximum thresholds for total points and fees for qualified mortgages in 2018 will be:
  • 3 percent of the total loan amount for a loan greater than or equal to $105,158.
  • $3,155 for a loan amount greater than or equal to $63,095 but less than $105,158. 
  • 5 percent of the total loan amount for a loan greater than or equal to $21,032 but less than $63,095.
  • $1,052 for a loan amount greater than or equal to $13,145 but less than $21,032.
  • 8 percent of the total loan amount for a loan amount less than $13,145. 

CFPB updates and creates new compliance tools
The Consumer Financial Protection Bureau has updated a number of compliance tools and added new tools to assist financial institutions in complying with the flurry of rule-making released the end of July and in August, including:

  • A 25-page detailed summary of the changes and clarifications to the TILA-RESPA Integrated Disclosure (TRID) rule. The amendments to TRID are effective Oct. 10, 2017, with optional compliance until Oct. 1, 2018. On Oct. 1, 2018, compliance with the amendments becomes mandatory.
  • The HMDA Filing Instructions Guide (FIG) for data collected in 2018 has also been updated to reflect amendments finalized in late August. The updated FIG can be found on the Resources for HMDA Filers webpage. The changes are itemized at the beginning of the FIG in the “version log.” 

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