I heard that the CFPB issued the final 2017 TILA –RESPA Rule which clarified and amended certain mortgage disclosure provisions under TRID. What is the effective date of the amendments?
The 2017 TILA-RESPA Rule was effective on October 10, 2017; however compliance was not mandatory on the effective date. Compliance with the 2017 TILA-RESPA Rule is mandatory for transactions for which a creditor or mortgage broker receives an application on or after October 1, 2018. It should be noted though that requirements for some post-consummation disclosures (Partial Payment Disclosure and Escrow Closing Notice) apply starting October 1, 2018 without regard to the application date.
Notwithstanding the October 1, 2018 mandatory compliance date, the 2017 TILA-RESPA Rule allows for optional compliance any time after October 10, 2017. During the optional compliance period, the provisions of the 2017 TILA-RESPA Rule can be implemented all at once or phased in over time. Given that many aspects of the 2017 TILA-RESPA Rule are favorable to creditors and mortgage brokers, it may be beneficial to phase in some of the amendments into the lending process prior to others.
Want more information from the team that's 'Bridging the Gap Between Risk and Compliance'?
Contact Britt Haven - 818.940.1200 ext. 421 or Alan Ridenour - 818.940.1210.
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Internal Audit is a function within an organization that independently evaluates the risks to the organization and the control environment that is in place. Typically, Internal Audit reports directly to the Board of Directors or Senior Management and is separate from all other departments to ensure that the evaluation remains independent.
Internal Audit is required if you, as a TMC Members, are approved or seeking approval from any of the GSEs, and it is also becoming a requirement for some states. A common deficiency in a Fannie Mae or Freddie Mac review is an inadequate or nonexistent internal audit program.
TMC Members approved or seeking to become approved with the GSEs must have, at a minimum, the following three items:
It appears I am required to have Internal Audit, can MQMR help me?
Of course! MQMR’s program has been developed over the previous 4+ years to ensure GSE requirements are met in addition to following the Institution of Internal Auditor (IIA) standards. MQMR has been able to leverage the findings from our clients' MORA and Freddie CORE reviews and conversations with the GSEs to adjust our program to meet Fannie/Freddie's non-published requirements.
MQMR is also offering a substantial Year End Risk Assessment Discount to all TMC Members who sign up for MQMR’s Internal Audit platform before December 31st! Reach out to Jen Peachman, Director of Member Engagement at TMC firstname.lastname@example.org or (440) 342-7817 or MQMR today to find out more about the amazing discount and how MQMR’s suite of services can benefit you in 2018 and beyond!
For additional information regarding MQMR’s services, please contact:
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The Joint Center for Housing Studies at Harvard University projected that as many as 13 million new U.S. households formed from 2010 to 2025 will be comprised of diverse segment families. AHA is proud of its strategic alliances with the following organizations representing these homeowners.
The Hispanic Homeowner Alliance (HHA)
The Hispanic Homeowner Alliance is pleased to partner with the Hispanic Wealth Project to provide free first year membership in the HHA. The Hispanic Wealth Project is a non-profit 501(c)(3) organization whose mission is to financially and educationally empower the Hispanic community in America. The Hispanic Wealth Project is built on the premise that all Americans benefit by the economic well-being of our Latino community. Its State of Hispanic Homeownership Report analyzes and evaluates population trends, educational achievements, income profiles and consumer attitudes as they relate to Hispanic homeownership. In 2015, it released a Hispanic Wealth Project Blueprint. The Blueprint, whose creation was chaired by the Honorable Henry Cisneros, outlines a business plan to triple Hispanic household wealth in the next ten years. Join the Hispanic Homeowners Alliance to help the Hispanic Wealth Project to advance the economic position of the Hispanic community in America.
To kick the Hispanic Homeowner Alliance and its partnership with the Hispanic Wealth Project, AHA Chairman & TMC Board Member, Phil Bracken with AHA Board Member, TMC Founding Partner and President of the National Association of Hispanic Real Estate Professionals, Gary Acosta wielded the gavel at the closing bell of the New York Stock Exchange on November 6, 2017.
The Black Homeowner Alliance (BHA)
The Black Homeowner Alliance is pleased to partner with the National Association of Real Estate Brokers (NAREB) to provide a first year free membership in the BHA. The National Association of Real Estate Brokers (NAREB) was founded in 1947, making it the oldest minority association in America. It was formed out of a need to secure the right to equal housing opportunities regardless of race, creed or color. Its national goal is to bring together the nation's minority professionals in the real estate industry to promote the meaningful exchange of ideas about our business and how best to serve our clientele. It strives to create an environment where creativity flourishes in both the workplace and the marketplace.
AHA, HHA and BHA offer TMC Members, Partners, Employees, Customers, Clients, former Clients, and Referral Partners benefits including:
Interested in joining America’s Homeowner Alliance? To register for membership: Click Here!
Use this Promotional Code specifically for TMC Members & Partner Companies: tmc2017
For more information on AHA, HHA or BHA, contact:
TMC Congratulates Our Lender Members That "Walk the Walk and Talk the Talk" - MBA Diversity & Inclusion Awards
Three of the five companies recognized this year by the MBA for their efforts in promoting diversity and inclusion in the workplace are members of The Mortgage Collaborative. For these companies, actions speak louder than words and each organization has demonstrated their ability to not only improve their communities, but also 'enrich and transform the industry' - said MBA Chairman, Dave Motley CMB. We applaud you for 'walking the walk, and talking the talk' when it comes to diversity and inclusion!
Market Outreach Strategies - First Community Mortgage:
For companies with less than 1,000 employees, First Community Mortgage is being recognized for providing educational and financial resources to minority homebuyers, including a very wide array of bilingual information and educational resources for potential Hispanic homebuyers.
Miguel Vega, Vice President of Diversity and Multicultural Lending, said FCM's Multicultural Lending Initiative has been in place since November 2016 and came about out of necessity. "Since 2000, Hispanics have accounted for 43 percent of the growth in U.S. households and have accounted for 56 percent of new household formations over the past five years," Vega wrote in the company's entry. "Additionally, our African-American market continues evolving and needs to be addressed intentionally with information, educational and financial resources."
The company's program focused on serving the middle Tennessee Hispanic Market and other customers from diverse ethnic origins through the formation of a dedicated Multicultural Lending Team. This team consists of an experienced bilingual Business Development Executive, an expert VP of Multicultural Lending Operations, four Multicultural Loan Officers and three Bilingual Customer Support and Lending Processing Junior Executives. The MCLI team reports directly to the Executive Vice President/Director of Lending for FCM.
To better serve its customer base, FCM identified the need for a mortgage loan product that would provide non-Social Security Number customers who have been paying taxes with an IRS-issued Tax Identification Number, with the ability to qualify for a mortgage. "With the partnership of our parent organization, combined we have dedicated $10 million in funds for 2017 to support our Home Opportunity Loan," Vega said. "Our ‘HO7' solution is a non-QM/ATR portfolio product which allows customers that have two years of income taxes being paid with a ITIN, to have access to financing the purchase of their primary residence."
Additionally, FCN started a corporate diversity educational program and multicultural operations resources targeted to its executives, loan officers and Operations teams to prepare the organization to better serve customers from diverse cultural backgrounds. Vega said locally, the initiative has been praised by the Tennessee Housing Development Agency, Middle Tennessee Association of Realtors, Great Nashville Realtors and Rutherford County Chamber of Commerce.
Market Outreach Strategies - New American Funding:
For companies with more than 1,000 employees, New American Funding is being recognized for the creation of its Latino Focus Committee, focused on the lending experience of Hispanic consumers and improving the Hispanic community through homeownership and the New American Dream Initiative, focused on raising awareness and increasing the level of homeownership in African-American communities through home-buying education. Marketing Director Rebecca Ray said the Latino Focus Committee has been in place for four years.
"The Latino Focus Committee develops services to enhance the quality of the lending experience among Hispanic consumers and aims to enrich the Hispanic community through homeownership," Ray wrote in the company's entry. "In 2016, New American Funding, a national mortgage banker, formed the New American Dream Initiative. The initiative seeks to raise awareness and increase homeownership in African-American communities by building consumer confidence fueled by home buying education and accessibility to relevant home loans."
The Latino Focus Committee seeks to enhance the quality of Latinos' experience with attaining a home loan, and enrich the Hispanic community through homeownership. Patty Arvielo, New American Funding's President and Co-Founder, created the Latino Focus initiative in 2013. When she started the initiative, 12 of her employees participated. Today, that number has grown to 184 employees.
"Patty brings her extensive experience, passion and cultural awareness of the Hispanic community to the mortgage industry," Ray said. "Patty knows the Hispanic community faces unique challenges when it comes to buying a home, including language barriers and frequently, a general lack of financial literacy. The Latino Focus Committee directly confronts these challenges with a variety of initiatives. They have developed several core outreach elements, including Spanish-language educational materials, and Spanish-language radio and billboard campaigns. The group has prioritized outreach that is specifically designed to educate the Hispanic community about their home ownership opportunities."
For example, New American Funding's Smart Start Home Buyer program, an initiative designed to educate first-time homebuyers about the process of purchasing a home, includes Spanish-language educational materials. On the operations side, the mortgage banker uses manual underwriting to accommodate cultural differences in earning, spending and credit that are common among Latinos. In 2016, Arvielo also collaborated with Freddie Mac to establish and launch a unique mortgage pilot program, Your Path, which makes affordable homeownership opportunities available to a broader demographic of borrowers in America.
Latino Focus also hosts educational events and workshops for professionals in the real estate industry. The seminars feature industry expert speakers, city officials and the community leaders. The events educate attendees about the cultural nuances of the millennial generation of Hispanic consumers, commonly known as "Hispennials."
"The initiative has garnered the interest of the industry as it has doubled in audience from its inception growing from 150 attendees per event to 350 per event," Ray said. "Due to popular demand, the events have expanded to a national level as of today. This initiative has been hosted in 13 cities nationwide."
New American Dream is a program that seeks to raise awareness and increase homeownership in African-American communities by building consumer confidence through home buying education and accessibility to relevant loan programs. Through this program, New American Dream aims to help families realize that owning a home is a feasible goal. Employees involved with this initiative help by shaping the communities focus. The committee who is involved with this initiative is able to identify and remove roadblocks by preventing the dream of homeownership.
Organizational Diversity and Inclusion - Pulte Mortgage:
Pulte Mortgage launched a program this year called "Inclusion Insights," which provides monthly all-inclusive learning sessions for management and their teams leveraging materials created by a cognitive neuroscientist. Sharyn Torrisi-Cartwright, Vice President of Human Resources, said the program was put in place this year. "We launched our overall D&I program in 2015; however this specific initiative was launched this year," she wrote in the company's entry. "We have partnered to launch all-inclusive learning to all team members with Pulte Mortgage.
The program, Torrisi-Cartwright said, "has been the most insightful way to create the dialog around diversity and inclusion. We have seen changes occur in the way our team views what Diversity and Inclusion really means. At Pulte, creating and maintaining a diverse and inclusive environment is not an ‘initiative,' rather, it's an ‘imperative.' Staying true to our ‘Ignite the Spark' values, we strive each and every day to ensure that our employees feel welcomed, included and enabled to succeed."
Pulte also engaged in a partnership with Dr. Steve Robbins, a cognitive neuroscientist and diversity expert, to provide employees with unique and interactive learning videos. "His teachings are in direct alignment with what we believe the true definition of diversity is--which goes much deeper than the ‘visual' and ‘physical' components that most limit their understanding to," Torrisi-Cartwright said. She added that the initiative has enabled Pulte to have "a great focus in the last 12 months and have really integrated D&I into everything that we do! It is the core of our culture."
The Collaborative congratulates our lender members on their 2017 MBA Diversity & Inclusion awards!
Additional members of The Mortgage Collaborative recognized by the MBA for their diversity & inclusion efforts are:
To read the full article from the MBA, click here.
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