Compliance Blog

Posted by Anthony Demangone

Here's a little of "this and that."

Exams.  Not too long ago, NAFCU produced a document to help credit unions navigate the examination process.  I recently updated that document, and the blog gains readers every day, so I think it is time to repost it. We made it available to anyone and everyone.  We hope you find it to be of use. Enjoy!   

NCUA website.  NCUA is updating its website again. As a creature of habit, I begin to shake when a regulator updates its website.  Especially a website that I use on a daily, if not minute-by-minute, basis. They do allow you to preview the new site and complete a survey. Hopefully, they won't change the URL address structure for their legal opinions, regulations and other guidance documents.  Sigh.

HPML and escrows.  The Fed recently issued a final rule regarding escrows.  I mentioned it earlier.  But the same day, they also issued a proposal.  Here's an overview of the proposal.  Note the proposed lengthening of the required escrow period for covered loans. 

The Board is also proposing a rule that would expand the minimum period for mandatory escrow accounts for first-lien, higher-priced mortgage loans from one to five years, and longer under certain circumstances, such as when the loan is delinquent or in default. The proposed rule would provide an exemption from the escrow requirement for certain creditors that operate in "rural or underserved" counties, as authorized by the legislation.

The proposal also would implement new disclosure requirements contained in the Dodd-Frank Act. Disclosures would be required at least three business days before consummation of a mortgage loan to explain, as applicable, how the escrow account works or the effects of not having an escrow account if one is not being established. The proposed rule also would require consumers to receive disclosures three days before an escrow account is closed. The Board is soliciting comment on the proposed rule for 60 days after publication in the Federal Register, which is expected shortly.

Comments are due May 2, 2011.