TRID 2.0 (effective Oct. 1, 2018)

TRID 2.0–Are You Ready? Have questions?

Thursday, September 27, 2018 10am-10:45am
NYMBA Member – COMPLIMENTARY!
Future Member $49.95
Space is limited–RSVPS needed!

We’re holding a live webinar presentation on September 27th—free for all New York MBA members!
TRID 2.0 addresses many of the pain points that our industry has struggled with over the past two years. The new rule is in effect & compliance is mandatory as of October 1, 2018.

This webinar will cover tolerance levels in motion, and significant changes including:

Construction loan disclosures
Re-disclosures after Rate Lock
Escrow closing notices
Co-ops and Loan Estimates
Compliance expert Linda Bow will outline changes included in TRID 2.0 and answer your questions. Linda Bow, CRCM, CUCE, BSACS is the Director of Compliance for New York Credit Union Association.

Linda has been in the regulatory compliance environment for over 30 years. In addition to her designations she has her Master’s degree in Business Ethics & Compliance and is a graduate of the ABA Stonier School of Banking with a Wharton School Leadership certification. Her extensive knowledge base is enhanced with her broad range of experience and expertise from overseeing loan production, servicing, pricing and selling. She has successfully managed financial institutions, compliance departments and staff through regulatory changes and implementations as well as developed and sustained Compliance Management structures focused on first, second and third lines of defense and annual risk assessments.

Manufactured Housing Title Conversion

To help ensure that affordable mortgage financing remains a viable option for manufactured home owners in New York, NYMBA supports proposed legislation, S6277A, which makes necessary changes to state law that allow lenders to comply with secondary and investor requirements.   Jeff Barringer and Marc Lifset of McGlinchey Stafford, New York MBA members, helped to craft the language in the bill that received Legislature approval.

While many manufactured homes are financed as personal property, the ability to finance land and a manufactured home with a mortgage is an attractive option for many homeowners seeking more favorable financing terms. Without the support and involvement of investors such as Freddie Mac, the availability of Land-Home Mortgages is limited.

Currently, in forty-four (44) states, a certificate of title establishes ownership of, and perfection of a security interest in, a manufactured home. All but New York also provide a formal statutory procedure for electing to convey and encumber a home as real property. Satisfying this conversion procedure legally converts the home to real property for all purposes.

DFS listens to New York MBA

Peter Dean, Executive Deputy Superintendent and Rholda Rickets, Deputy Superintendent of New York State Department of Financial Services met with New York MBA Executive Board members regarding Federal legislation mandating Temporary Authority for Loan Officers; the new state regulation mandating Credit Reporting Agency Registry and proposed Online Notarization.

DFS meeting 7.19.2018

FHA Lender Roundtable

July 19, 2018:  Philadelphia Homeownership Center of U.S. Dept. of HUD came to New York to listen to lenders, provide updates, and share ideas to benefit FHA borrowers, homeowners and lenders.

FHA Jim & Julie 7.19.2018

Julie Shaffer, Director HUD’s Philadephia HOC
and James Bopp, New York MBA President.

FHA Steven & Jacki 7.19-2018

FHA Group Pic 7.19.2018

 

AMC Licensing moves forward

Senate and Assembly approve State AMC Licensing Bill–Awaiting Governor Cuomo’s signature

June 21, 2018:  Both branches of the NYS Legislature approved the long sought after AMC licensing bill, as required by Dodd-Frank.  When approved, all 50 states will be compliant by having passed legislation that establishes guidelines  for  Appraisal Management Companies, a federal mandate effective August 2018.

Federal Regulatory Relief Legislation a Reality

May 24, 2018:  President Trump signed S.2155, the Economic Growth, Regulatory Relief and Consumer Protection Act.  The full House passed the bill earlier in the week by a vote of 258-159. This legislation is unchanged from that which passed the Senate in March by a filibuster-proof bipartisan margin of 67-31. This legislation contains a number of MBA-supported provisions, such as:

  • SAFE Act amendments to provide 120 days of transitional authority for MLOs to originate when leaving a depository to join a sponsoring non-bank (or when crossing state lines);
  • Applying TILA consumer protections to PACE/energy efficiency mortgage products;
  • Added safeguards to protect veterans, surviving spouses and service members who utilize the VA Home Loan program’s IRRRL refinancing product;
  • An improved, more workable regulatory regime for the eligibility of High Volatility Commercial Real Estate (HVCRE) construction loans; and,
  • Partial TRID and HMDA relief

Source: MBA

Thank you to those who took action on these important issues!  Your advocacy makes a difference.

Trump approves Regulatory Relief Legislation

Regulatory Relief Legislation receives Trumps approval

May 24, 2018:  President Trump signed S.2155, the Economic Growth, Regulatory Relief and Consumer Protection Act.  The full House passed the bill earlier in the week by a vote of 258-159. This legislation is unchanged from that which passed the Senate in March by a filibuster-proof bipartisan margin of 67-31. This legislation contains a number of MBA-supported provisions, such as:

  • SAFE Act amendments to provide 120 days of transitional authority for MLOs to originate when leaving a depository to join a sponsoring non-bank (or when crossing state lines);
  • Applying TILA consumer protections to PACE/energy efficiency mortgage products;
  • Added safeguards to protect veterans, surviving spouses and service members who utilize the VA Home Loan program’s IRRRL refinancing product;
  • An improved, more workable regulatory regime for the eligibility of High Volatility Commercial Real Estate (HVCRE) construction loans; and,
  • Partial TRID and HMDA relief

Thank you to those who took action on these important issues!  Your advocacy makes a difference.

Senate Approves Montgomery as FHA Commissioner

Finally, the Trump Administration has an FHA Commissioner.

By a comfortable 74-23 vote yesterday, the Senate approved Brian Montgomery as Assistant Secretary for Housing and FHA Commissioner, ending a nine-month process that saw his nomination repeatedly held up by Senate rules and a backlog of other Trump Administration nominations. Twenty-five Democrats joined 49 Republicans in approving Montgomery.

The Mortgage Bankers Association and other industry trade groups had pushed hard for Montgomery’s approval. Following yesterday’s vote, MBA President and CEO David H. Stevens, CMB, issued a statement, praising the Senate vote and pledging to work with Montgomery on key housing issues.

“MBA commends the Senate for confirming Brian Montgomery to lead the Federal Housing Administration,” Stevens said. “His experience, knowledge and ability will ensure his success in this position. MBA fully supports FHA’s efforts to assist low and moderate income Americans and first-time homebuyers. We look forward to working with Brian Montgomery and the FHA team, and continuing to work with Secretary Ben Carson, to ensure they succeed in their mission.”

This will be Montgomery’s second stint as FHA Commissioner, having previously served from 2005 to 2009, under both the George W. Bush and Obama Administrations. During that period, MBA and other industry trade groups said in a March letter to Senate leadership, “he realized the immense counter-cyclical benefits that FHA can provide in the middle of the housing crisis. He also led HUD’s response to Hurricane Katrina and chaired the Hurricane Recovery and Response Center at HUD headquarters.”

The Trump Administration initially nominated Montgomery in September 2017. The Senate Banking favorably reported his nomination in late November by an 18-5 bipartisan vote; however, under Senate rules and procedures, and given that the full Senate did not hold a floor vote on his confirmation before year’s end, his nomination was “returned” at the end of 2017. He was nominated again in early January; the Banking Committee once more favorably reported his nomination later that month.

“Brian brings a wealth of housing knowledge and experience to HUD having held this position in two previous administrations, and we are excited to welcome him back to the Agency,” said HUD Secretary Ben Carson in a statement. “FHA’s work is critical to HUD’s mission of advancing sustainable homeownership opportunities and quality affordable housing for all Americans. Brian understands this better than anyone and will be ready on day one to address the challenges of today’s housing market.”

“I’m honored to have the opportunity to serve with Secretary Carson and the team at HUD to further equal access to affordable rental housing and homeownership opportunities and seek solutions to restore vitality to the housing market,” Montgomery said in a statement.

Ahead of yesterday’s Senate vote, the MBA Mortgage Action Alliance issued a Call to Action, urging its members to contact their senators in support Montgomery’s nomination (https://action.mba.org/mba/app/write-a-letter?0&engagementId=478493).

“FHA is the largest insurer of mortgages in the world and is a critically important source of affordable mortgage credit, especially for first-time and low- and moderate-income homebuyers,” said MBA Senior Vice President for Legislative and Political Affairs Bill Killmer. “Competent leadership is needed for such an important agency and Brian’s years of experience, most notably his previous term as FHA Commissioner under both the George W. Bush and Obama administrations, make him an excellent candidate for this position.”

Once on board, Montgomery will have his hands full. MBA has identified several critical management priorities, including enhancing efficiency and technology deployment, clarifying existing lender guidance and ensuring the long-term financial stability of the FHA program.

Source: Mortgage Link
May 24, 2018
Mike Sorohan msorohan@mba.org