IMA Prime Times: January 15, 2018 Iowa Mortgage Association

January 2018


President's Message

Association Updates

Industry News


IMA Offers Much to Look Forward to in 2018
Happy New Year! I hope everyone was able to spend time with friends and family during the holiday season. Now it's time to look to the year ahead, plan your goals and how to get there. While you are planning your year, please make sure to include the Iowa Mortgage Association's (IMA's) events on your calendar. The IMA Spring Conference is just around the corner. It will be held at the Marriott in Cedar Rapids on March 27, 2018. This is also the event where we announce the President’s Club and Winners Circle Loan Production Awards for 2017. You should have received an email at the beginning of the month to submit an entry form. Please take a moment to complete and submit the form; I look forward to recognizing you in March!

Have a wonderful January and stay warm!

Marcy Wagner
TitleCore National


Renew Your IMA Membership Today
It’s time to renew your Iowa Mortgage Association (IMA) membership for 2018. Renewal forms were mailed in early December and are also available on the IMA website. The IMA is planning another great year and making significant strides to improve the mortgage industry. We encourage you to join forces with your fellow mortgage professionals and take advantage of all the IMA has to offer. 

Save the Date: IMA Spring Conference is March 27
The Iowa Mortgage Association (IMA) Spring Conference will be held on March 27 at the Cedar Rapids Marriott. The conference will include sessions on consumer behavior, a compliance update, eClosings and more. The IMA President’s Club and Winners Circle Awards will also be presented. The cost for attending is $175 for members and $350 for nonmembers. Those rates go up to $195 for members and $370 for nonmembers after March 21. Learn more or register.


Regulators Expect 'Good Faith Effort' to Comply With HMDA
Three regulatory agencies have issued statements regarding the evaluation of a financial institution’s compliance with the Home Mortgage Disclosure Act (HMDA), implemented by Regulation C. Specifically, for HMDA data collected in 2018 and reported in 2019, the regulators do not intend to require data resubmission unless data errors are material. In addition, they do not intend to assess penalties with respect to errors in data collected in 2018 and reported in 2019.

The regulatory agencies indicated they recognize “the significant systems and operational challenges needed to adjust to the revised regulation.” As such, through this supervisory approach, examination staff will give credit to institutions' good faith compliance efforts, and the approach will help institutions identify compliance weaknesses. See the Consumer Financial Protection Bureau's (CFPB’s) Dec. 21 announcement, FDIC FIL-63-2017 or the Office of the Comptroller of the Currency (OCC) Bulletin 2017-62 for more details. At the time of this publication the Federal Reserve Board (FRB) has not issued a similar statement but expectations are the FRB would follow the other prudential regulators' lead.

CFPB Releases New HMDA Tools
The Consumer Financial Protection Bureau (CFPB) has released two new tools to assist filers with the new Home Mortgage Disclosure Act (HMDA) requirements:
  • HMDA Check Digit ToolThis tool will serve two functions. The first is to generate a two character check digit when you enter your bank’s Legal Entity Identifier (LEI) and loan or application ID. The second is to validate that a check digit is calculated correctly for any complete Universal Loan Identifier (ULI) entered. 
  • Rate Spread Calculator for 2018This tool will provide rate spreads for HMDA-reportable loans with a final action taken date on or after Jan. 1, 2018. Banks should continue to use the existing Federal Financial Institutions Examination Council (FFIEC) rate spread calculator for their 2017 HMDA loan data. 

CFPB to Reconsider HMDA Rule
Just before the end of 2017, the Consumer Financial Protection Bureau (CFPB) issued a public statement regarding implementation of the Home Mortgage Disclosure Act (HMDA), noting that it plans to reconsider aspects of the mortgage data rule, stating that it “intends to engage in a rulemaking to reconsider various aspects of the 2015 HMDA Rule such as the institutional and transactional coverage tests and the rule’s discretionary data points.” According to the CFPB, this rulemaking will likely re-examine, among other things, lending-activity criteria that determines whether data and transactions must be reported.

At this point, it is unclear how the regulations will change, but it appears likely that the modifications will reduce the amount of information about borrowers that banks and other lenders are required to submit to regulators. Further, the number and types of institutions required to report certain information could be reduced. For now, lenders will have to comply with the rule as it was finalized by the CFPB in 2015

NFIP Authorization Extended to Jan. 19
Without Congressional reauthorization, the National Flood Insurance Program (NFIP) is set to expire on Jan. 19, 2018. Under current law, the Federal Emergency Management Agency (FEMA) may not enter into a new flood insurance contract after a lapse in authority; meaning, loans secured by properties located in special flood hazard could not be consummated until the NFIP is reauthorized and flood insurance can be obtained.

In preparation for a lapse, FEMA has published guidance for Write Your Own private insurance companies on how to handle a potential lapse in NFIP authority. The guidance provides information on new policies and renewals during a lapse period. In addition, the guidance includes frequently asked questions and a sample letter that may be used to help Write Your Own companies communicate the effects of a lapse to a prospective policyholder. FEMA’s guidance (Memo W-17069) can be found here.

PRIA Seeks Document Rejection Stories
The Property Records Industry Association (PRIA) Document Rejections Work Project Team is seeking stories of documents being rejected so that they can find solutions and develop best practices. The PRIA is seeking stories from people who submit documents to Iowa County Recorders either in person or electronically via the Iowa Land Records E-Submission service. Document submitters can share their document rejection stories here. Submitters can help the work project team define the terms for rejections here. Results of this effort will be shared at the upcoming PRIA Winter Symposium, Feb. 26 through March 1 in New Orleans.

$7.4 Million in Housing Grants to Benefit Iowa Families
This holiday season, 850 Iowa families will receive affordable housing, thanks to a collaborative effort between community housing providers, financial institutions and the Federal Home Loan Bank of Des Moines (FHLB Des Moines or the Bank). FHLB Des Moines recently awarded $2.5 million in grants from its Competitive Affordable Housing Program to provide housing for low-income families, seniors, persons with disabilities, homeless and at-risk youth in the state of Iowa. FHLB Des Moines also contributed $4.9 million throughout the year to assist Iowa families with down payment and closing cost expenses.

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