The mortgage process can be daunting, with its myriad regulations and requirements. Among these, the TILA-RESPA Integrated Disclosure (TRID) Rule, implemented by the Consumer Financial Protection Bureau (CFPB) in 2015, stands out for its impact on disclosure timing requirements for mortgage lenders. Similar to the fee tolerance requirements discussed in Part 1 of this series, […]

Fannie Mae recently published Fair Servicing Best Practices (“FSBP”). Developed with input from more than 30 mortgage servicers and community advocacy groups, the FSBP is intended to ensure Fannie Mae servicers are aware of the expectations that servicers will treat all borrowers fairly and consistently, and comply with the Equal Credit Opportunity Act (“ECOA”), the […]

This is the first entry of a three-part refresher series covering various aspects of the TILA-RESPA Integrated Disclosure Rule.  The TILA-RESPA Integrated Disclosure (TRID) Rule, implemented by the Consumer Financial Protection Bureau (CFPB) in 2015, revolutionized the mortgage industry by consolidating several forms and disclosures into two main documents: the Loan Estimate (LE) and the […]

Following the publication of this article, the Public File deadline was adjusted to January 1, 2026. The recent lawsuit challenging the Community Reinvestment Act (CRA) File Rule may have added uncertainty to the implementation timeline, but one crucial aspect remains unchanged: your CRA Public File must be updated and readily available by April 1, 2024. […]

(Originally published in ABA Risk and Compliance, July/August 2023) Bill Fair and Earl Isaac created the first modern credit scoring system, the Credit Application Scoring Algorithms, in 1958, and the first FICO score was introduced in 1989. Since then, the use of credit algorithms has become ubiquitous in the lending industry. These algorithms use statistical […]

It’s no secret that mortgage lenders have seen a sharp decrease in origination volumes over the past two years. Higher interest rates coupled with a shortage in housing inventory translate into a market environment where origination volumes are likely to remain depressed for the near future.    The mortgage industry must explore different avenues for […]

(Originally published in ABA Risk and Compliance, November/December 2023) In lending, discretion can take several forms, including exceptions and overrides. An exception is an application whose outcome is not fully consistent with credit underwriting and pricing policies. The variation can be either in the underwriting outcome, or in loan terms and conditions, such as interest […]

As the submission March 1 deadlines loom for annual CRA and HMDA data reporting, Compliance Officers can sometimes feel a bit lost in the woods. While the details of filings are always important, it’s critical to take the time to pick your head up and look at your data at a macro level. This past […]

Unlocking Insights: Analyzing the 2022 CRA Peer Data for Small Business, Small Farm and Community Development On December 20, 2023, the three Federal banking agency members of the Federal Financial Institutions Examination Council (FFIEC) with Community Reinvestment Act (CRA) responsibilities — the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance […]

On November 8, 2023, the Consumer Financial Protection Bureau (“CFPB”) entered into a consent order with a major bank to resolve allegations of violations of the Equal Credit Opportunity Act (“ECOA”) and Regulation B. Among other allegations, the CFPB asserted that the lender “failed to provide applicants with an accurate and adequate statement of the […]