Today, Ginnie Mae clarified in an industry forum that its APM 21-06 seasoning requirements for the VA IRRRL Refinance of a Modified Loan are measured from the contracted first payment due date under a modification agreement. This arises in cases where the VA loan being refinanced has been modified and re-pooled.

Ginnie Mae clarifies its MBS Guide with respect to seasoning of VA IRRRLs that are a “Refinance of a Modified Loan.” Issuers had challenged Ginnie Mae’s buy out demands that claimed insufficient seasoning when measured from the first payment date of an intervening modification of the loan, even though sufficiently seasoned from the first payment under the pre-modified loan terms.

Issuers should be aware that Ginnie Mae interpreting its MBS guide in a manner that departs from VA circular 26-19-22, and the plain reading of statutory language with respect to the beginning and ending dates used to determine seasoning of VA IRRRLs. These distinctions have resulted in MBS issuers receiving unanticipated Ginnie Mae buy out demands for insufficient

Today, the Financial Crimes Enforcement Network (FinCEN), announced final rulemaking on anti-money laundering (AML) customer identification program (CIP) requirements for banks not subject to federal functional regulator supervision. This new rulemaking subjects those non-supervise

Oregon Gov. Kate Brown issued Executive Order 20-37 today extending the emergency period under HB 4204 through December 31, 2020. The emergency period previously ran from March 8th through September 30. HB 4204 imposes mortgage payment forbearance requirements and foreclosure moratorium on all real property loans.

June 30, 2020, Oregon Governor, Kate Brown, signed sweeping mortgage payment forbearance and foreclosure moratorium provisions into law. Virtually all loans secured by real property and certain installment contracts secured

Housing is a fundamental necessity of all people. Access to housing is problematic for many with lower incomes, particularly those with limited English proficiency or disabilities that may require accommodations to even begin the process.

The slippery slope of regulation by software has apparently been traversed again. On a call with software developers regarding HMDA, the Consumer Financial Protection Bureau ("Bureau") indicated that the Universal Loan Identifier ("ULI") is not case sensitive.

South Carolina H 3627 proposes penalty of 3x payment if mortgagors fail to apply at least 30% of a mortgagee's loan payment toward the principal balance of the loan. In so doing, it both mislabels borrowers as mortgagee and lenders as mortgagors (it's the opposite) and misunderstands the mortgage math

The California DBO has been aggressively enforcing the CFL without clarifying lead provider ambiguities in the law. Lead providers are no longer an emerging industry, they constitute core marketing in this digital age, yet the California Financing Law (“CFL”) is an analog statute with relevant

The CFPB's en banc appeal in the PHH Corporation, et al v. Consumer Financial Protection Bureau case was decided today. The U.S. Court of Appeals for the District of Columbia Circuit reversed the 3 judge panel decision on the constitutionality of a single director but reinstated the panel’s

The Consumer Financial Protection Bureau, OCC, and FDIC recently released statements promising leniency with regard to resubmission of 2018 HMDA data. The Agencies' statements recognize the additional complexity in data collection and reporting caused by new data requirements and mandatory reporting

Opportunity for you to influence new regulations prior to notice and comment period. In my role on the Oregon Division of Financial Regulations' Rulemaking Advisory Committee for the drafting of the permanent regulations implementing the Mortgage Loan Servicer Practices

Signed into law on August 2, 2017, the Oregon Mortgage Loan Servicer Practices Act (MLSPA) becomes operative January 1, 2018. Temporary regulations implementing the MLSPA will be published tomorrow, giving covered mortgage loan servicers only 60 days to get licensed.

The CFPB has recently required both depository institutions and independent mortgage companies to increase their compliance staff. A number of companies are struggling to understand how many compliance resources are needed. We think ratios are a crude and relatively ineffective tool in this evaluation.

Believe it or not the top 3 questions about getting a LEI are: 1. What is a LEI? 2. Where do I get a LEI? and 3. Is getting a LEI free? Hint: t isn't a flower necklace, you can't get one at the airport in Hawaii, and since the government requires it and a third party provides it you know

Will HMDA's 23 character ULI handle production when the ULI can never be reused in the future? What if 18 characters are taken up by a non-consumer identifying substitute for the MERS ID, leaving only five? What happens when we add branch identifiers?

The Code of Federal Regulations is where federal administrative laws are codified, which are also referred to as “rules.” The Code of Federal Regulations is written by federal agencies authorized by Congress to clarify the statutes that Congress passes.

The Bureau’s eRegulations parsing errors were the topic of user tips in my previous post. This post describes where and how to verify the text. For the purposes of this article, we examine the parsing error in the header of 12 C.F.R. § 1026.36(d)(1). The eRegulations heading reads “Payments

Parsing errors require users to exercise caution when using the Consumer Financial Protection Bureau's eRegulations. Though once a favored tool because of its simple user interface, I no longer advocate its use due to a number of recently identified parsing

The Federal Housing Finance Agency has directed Fannie and Freddie to develop a Uniform Mortgage Data Program of which the Uniform Closing Dataset (UCD) is one component. The goal is to better support the CFPB's new Closing Disclosure. The UCD will