The Future Of Mortgage Lending

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We need to join together and support what is best for the consumers we serve in the primary mortgage marketplace.

EQUAL STANDARDS AND ACCOUNTABILITY

SOLUTION AND CALL TO ACTION:

Revise final rule making as it pertains to 3% points and fees cap under QM and make sure that all channels are treated equally for the benefit of consumers, competition, and small businesses that serve consumers across the United States.

  • Remove creditor-paid compensation/origination in the 3% cap on points and fees to loans being brokered on the wholesale channel when included in the rate sheet (treat channels fairly and supports competition and choice for consumers as well as correcting many other issues that can arise as proven by the example and numbers shown however they are viewed)  

    Require that all Mortgage Brokers have the same set % margin of lender-paid compensation with all their investors.  This will avoid any concerns of steering, fair lending issues, compensation issues on loan type, etc.  Potentially have a small exceptional range for niche lenders that may not offer the company set % margin (such as off by 0.125%) if documented in the best interest of the consumer to utilize that investor.

  • Make sure YSP and SRP are always treated identically on future RESPA/TILA disclosures and regulations facing the industry.  To make disclosures easy to understand, only show the rebates or costs consumers actually receive or actually pay, to remove YSP on creditor-paid wholesale transactions in line with all channels.  The note rate, APR, and adjusted origination fees MUST be clear for consumers to compare and understand that are disclosed identically.  *** 11/20/2013 UPDATE.  After a final rule making today and reading the text, It appears that the CFPB acknowledged and confirmed simplifying and creating transparent loan disclosures equal on all channels on creditor-paid transactions is a priority.  More updates to follow, but this would be a huge win for consumers starting in August of 2015 when these changes are to take place.  We commend the CFPB.          More:

    “The Bureau noted in the proposal that it believes consumers may not benefit from any disclosure of interest rate-based compensation, citing the Board’s Regulation Z restrictions on the compensation of loan originators.” 

    “Furthermore, the Bureau believes that, on balance, the exemption will simplify the credit process without undermining the goal of consumer protection or denying important benefits to consumers. Accordingly, the Bureau is exempting the disclosures required pursuant to  826 § 1026.19(e) from the requirement in TILA section 128(a)(18) to itemize fees received by loan originators from the creditor”

Here is a link of proposed new loan disclosures from the CFPB.

                
Here are some of the names of businesses, associations, consumers, lenders, and anyone that supports consumer choice.  Join us! 

Please contact us at info@thefutureofmortgagelending.com to add your name.


Vantage Mortgage Group, Inc. (Oregon)

Associated Mortgage Group (Oregon)

Mortgage Team 1, Inc. (Alabama)

Platinum Lending Solutions (Oregon)

* Avelloe Mortgage Corp. (Oregon)

* AMC Mortgage Corporation (Maryland)

* NAMB, The Association of Mortgage Professionals

* Crown Lending, Inc.  (Texas)

* Karen Sawyer, Mortgage Loan Originator (Washington)

* SMC Home Finance (North Carolina)

* Amtrust Mortgage Funding, Inc. (Indiana)

* Premier Nationwide Lending (Texas)

* Stacie Hartman, Account Executive CMG Financial  (Oregon)
   
Advanced Funding (Utah)

* Heritage National (Michigan)

* First Class Financial Services (Colorado)
   
IRM Home Loans (California)

D.A. Griffin Financial, LLC (Kentucky)

Stepping Stone Mortgage (Oregon)

Foundation Mortgage Corporation (South Carolina)

* Kimberly Buttle - Metropolitan Mortgage Group Inc. (Washington)

Andrew Chung (Account Executive) - Rushmore Home Loans (Oregon)