IBA’s compliance webinars are a continuing series. Brought to you by the IBA compliance staff they offer timely information, addressing key regulatory issues when you need it. The webinars keep you informed and ready for the challenges of the changing regulatory financial services environment.
The CFPB recently released a final rule implementing a new exemption the requirement to escrow for first lien Higher Priced Mortgage Loans (HPMLs). To be eligible for the exemption, institutions must meet certain criteria based on their asset size, loan volume, where they currently make loans and current escrow activity. If your bank in interested in discontinuing your current HPML escrow program or has been limiting your interest rate margins to avoid making HPMLs and the accompanying escrow requirement, this webinar is will review the existing HPML rules and exemptions PLUS assist you in determining if your institution originates HPMLs, the requirements related to these loans, and if your bank is eligible for this new escrow exemption. Webinar topics include:
- Covered loans
- Process for determining rate spread
- Escrow requirement – what must be included in the escrow
- Loan exemptions
- Existing small creditor exemption
- New “insured institution” – low volume exemption
- Cancellation provisions
- Appraisal requirement – coverage & requirements of appraisal (certified appraiser, etc.)
- Loan exemptions
- 2nd appraisal rule
- Copy requirement/timing/no waiver