Texas Finance Commission Revises §155.2 (7 TAC Chapter 155) and Payoff Statement Form for Home Loans

In Client and Friends Memos, Texas Legislation by BMG Memorandum

In the September 11, 2020, issue of the Texas Register (45 TexReg No. 36) the Finance Commission of Texas, on behalf of the Department of Savings and Mortgage Lending, the Office of the Consumer Credit Commissioner, and the Texas Department of Banking, adopted amendments to §155.2 (7 TAC Chapter 155) and the Payoff Statement Form embedded in §155.2 as Figure: …

Flood Insurance Proposed Interagency Questions and Answers

In Client and Friends Memos by BMG Memorandum

In the July 6, 2020, issue of the Federal Register (85 FR 40442, click here), the  Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), the Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA), (collectively the “Agencies”), jointly published proposed Interagency Questions and Answers Regarding …

CFPB Proposes Creation of New Category of Qualified Mortgages

In Client and Friends Memos by BMG Memorandum

In the August 28, 2020 issue of the Federal Register (85 FR 53568, click here), the Consumer Financial Protection Bureau (CFPB) published a proposed rule, with a request for public comment, that would create a new category of qualified mortgages in §1026.43(e)(7) for first-lien, fixed-rate covered transactions that have met certain performance requirements over a 36-month seasoning period, are held …

FHA Mortgagee Letter 2020-27 Extends Foreclosure and Eviction Moratorium Extension in Mortgagee Letter 2020-19

In Client and Friends Memos, FHA by BMG Memorandum

On August 27, 2020, the Federal Housing Administration (FHA) issued Mortgagee Letter 2020-27 (ML 2020-27). ML 2020-27 extends the foreclosure and eviction moratorium originally issued in Mortgagee Letter 2020-04 and extended in Mortgagee Letter 2020-19 for borrowers with FHA-insured Single Family mortgages covered under the Coronavirus Aid, Relief, and Economic Security (CARES) Act for an additional period through December 31, …

Fannie Mae and Freddie Mac Announce Adverse Market Refinance Fee

In Client and Friends Memos by BMG Memorandum

On August 12, 2020, Fannie Mae, in Lender Letter 2020-12 (click here-12 ), and Freddie Mac, in Bulletin 2020-32 (click here-32), announced a 50 basis point (0.500%) adverse market refinance fee (called a “loan-level price adjustment” and “LLPA” in Lender Letter 2020-12 and a “Market Condition Credit Fee in Price” in Bulletin 2020-32). For purposes of this memorandum this new …

FHA Mortgage Letter 2020-26 – EAD Module

In Client and Friends Memos by BMG Memorandum

On August 18, 2020, the Federal Housing Administration (FHA) issued Mortgagee Letter 2020-26 (ML 2020-26) announcing the availability of a new Electronic Appraisal Deliver module (EAD) for the FHA Title II Single Family forward mortgage program. Mortgagees may begin using this new EAD on the FHA Catalyst platform on and after September 1, 2020. Full Memorandum

Loss Mitigation Opinions under Regulation X Amended by CFPB Interim Final Rule Adding Certain COVID-19-related Loss Mitigation Options

In Client and Friends Memos by BMG Memorandum

In the June 30, 2020 issue of the Federal Register (85 FR 39055), the Bureau of Consumer Financial Protection (CFPB) issued an interim final rule (IFR) amending §1024.41 of Regulation X by revising paragraph (c)(2)(i) and adding paragraph (c)(2)(v) to temporarily permit mortgage servicers to offer certain loss mitigation options based on the evaluation of an incomplete loss mitigation application …

CFPB Proposed Rule to Amend Higher Priced Mortgage Escrow Exemption

In Client and Friends Memos by BMG Memorandum

In the July 22, 2020 issue of the Federal Register (85 FR 44228, click here) the Bureau of Consumer Financial Protection (Bureau) published a proposed rule, with a request for public comment, that proposes to amend the higher-priced mortgage loan (HPML) escrow exemption in §1026.35 of Regulation Z to exempt any loan made by an insured credit union or insured …

CFPB Proposed Rule to Amend General Qualified Mortgage Loan Definition

In Client and Friends Memos, QM/Ability to Repay by BMG Memorandum

In the July 10, 2020 issue of the Federal Register (85 FR 41716, click here) the Bureau of Consumer Financial Protection (Bureau) published a proposed rule, with a request for public comment, that proposes to amend the General Qualified Mortgage Loan definition in §1026.43(e)(2) of Regulation Z (General QM Loan) by removing the General QM Loan definition’s 43 percent total …