IMA Prime Times: September 2018 Iowa Mortgage Association

September 2018


President's Message

Association Updates

Industry News

Thanks for a Great Year!
This is my last president’s message. I want to thank you for allowing me to serve as your president for the past year. It has truly been an honor. I will hand over the presidency to Laura Kay Sheely next month at the IMA Convention in West Des Moines. If you have not signed up to attend the convention, now is the time! Come network with your friends and listen to the great speakers that are coming in to present. I look forward to seeing everyone!

Marcy Wagner
TitleCore National

Why Attend the IMA Fall Conference?
The 2018 Iowa Mortgage Association (IMA) Fall Conference will be Oct. 1-3, at the West Des Moines Marriott Hotel. Here are three reasons not to miss it!

  1. Outstanding speakers – Sessions cover topics like the Sales Process from Joe Micallef, Mortgage Compliance from Ronette Schlatter, High Tech and High Touch Mortgage Origination from Pat Sherlock and a closing session from Paul Long, sharing his infectious message about Fundamism.
  2. Networking with mortgage peers – Sessions and breaks are made for networking, and you’ll be able to get ideas and learn from those who know best – your peers in the mortgage industry.
  3. Fun – We won’t forget to bring the fun, too! With a reception, prizes, engaging speakers and time for networking with exhibitors, the Fall Conference is a great opportunity to learn and have fun all at the same time.

Learn more and register for the IMA Fall Conference.

CFPB Issues HMDA Partial Exemption Rule
On Aug. 31, 2018, the Consumer Financial Protection Bureau (CFPB) issued an interpretive and procedural rule to implement and clarify changes made by section 104(a) of the Economic Growth, Regulatory Relief and Consumer Protection Act (the act) to the Home Mortgage Disclosure Act (HMDA). The CFPB issued an executive summary of the interpretive rule to provide an overview for reporting institutions. 

The rulemaking implements the act’s provisions intended to provide regulatory relief for certain low-volume HMDA reporters by adding a partial exemption from HMDA’s reporting requirements for certain data points. An insured depository institution does not need to collect or report certain data with respect to closed-end mortgage loans if it originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years. Similarly, an insured institution does not need to collect or report certain data with respect to open-end lines of credit if it originated fewer than 500 open-end lines of credit in each of the two preceding calendar years. The act further provides that these partial exemptions are NOT available to an insured depository institution if it received an unsatisfactory rating during a recent Community Reinvestment Act (CRA) examination.

The August 2018 interpretive rule issued by the CFPB clarifies:

  • Which originated mortgage-secured closed-end loans and lines of credit should be counted when determining if an institution qualifies for the partial exemption.
  • The requirement related to satisfactory CRA ratings.
  • Which data points are covered by the partial exemption.
  • The effective date of the partial exemption. 

The CFPB has also updated its Regulatory and Reporting Overview Reference Chart and Filing Instructions Guide to reflect the proper LAR reporting codes for exempt loans in each of the exempted data point categories.   

Geocoding System and HMDA Product Updates
The Federal Financial Institutions Examination Council (FFIEC) announced the availability of the 2018 Geocoding System with updated 2018 Census demographic data. The FFIEC Geocoding/Mapping System helps HMDA and CRA reporters meet their legal requirements for reporting census tract information of collateral properties. FFIEC also released the 2018 Census Data Products, which includes the FFIEC Census Windows Application and FFIEC Online Census Data System (formerly FFIEC Census Reports). The FFIEC Census Windows Application is a downloadable Windows-based tool that allows users to search and export data, and to create reports using the census data that is published in the HMDA and CRA aggregate and disclosure reports.

On a HMDA-related note, the Consumer Financial Protection Bureau (CFPB) released its file format verification tool (FFVT) for HMDA data collected in 2018 and submitted in 2019. Using the FFVT, HMDA reporters can test whether their HMDA files meet the formatting requirements laid out in the HMDA filing instructions guide. Access the tool.

2019 Reg. Z Thresholds Set
The Consumer Financial Protection Bureau (CFPB) has announced 2019 changes in dollar thresholds for several Regulation Z provisions governed by the CARD Act, the Home Ownership and Equity Protection Act (HOEPA) and the Dodd-Frank Act. The thresholds are based on changes in the Consumer Price Index and take effect on Jan. 1, 2019.

The HOEPA loan threshold will increase to $21,549, and the HOEPA points-and-fees trigger will rise to $1,077. For Qualified Mortgages, points and fees cannot exceed:

  • 3 percent of loans of $107,747 or more.
  • $3,232 for loans between $64,648 and $107,747.
  • 5 percent for loans between $21,549 and $64,648.
  • $1,077 for loans between $13,468 and $21,549.
  • 8 percent for loans of less than $13,468. 

Read the CFPB’s final rule adjusting the thresholds in the Aug. 27, 2018 Federal Register.

New Reporting Requirements and Enhancements for USDA RD’s Guaranteed Home Loan Program 
Lenders using the U.S. Department of Agriculture (USDA) Rural Development’s (RD’s) guaranteed home loan program are now required to provide status reports for all loans on a monthly basis, as well as use new electronic status reporting (ESR) enhancements. As part of the enhancement lenders must also complete electronic status and default report corrections. Please see USDA’s LINC training and resource library for training opportunities and the ESR user guide for assistance with accessing the rejects needing corrections and completing the reject corrections. Authorized lenders may access the ESR correction system here. Assistance with the ESR correction system can be directed to or via phone at 1-877-636-3789 option 1. 

Revised RD Form 3555-21 Request for Single Family Housing Loan Guarantee
An advance copy of the new Form RD 3555-21 is now available for lender process and IT development purposes. This form will be fully adopted on Oct. 1, 2018, when it will be posted to the USDA eForms and be pre-filled via USDA’s Guaranteed Underwriting System (GUS). The U.S. Department of Agriculture (USDA) Rural Development (RD) will discontinue use of Form RD 3555-21 (with revision date of June 2016) on Nov. 1, 2018, and all loan packages much include the new Form RD 3555-21.

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