Amy Avitable, Director of Regulatory Compliance, TCS BaNCS

The new Regulation Z, RESPA and Regulation B mortgage reform rules go into effect. They usher in an unprecedented amount of legal and financial risk for mortgage lending, as many of the new rules carry civil liability as well as statutory damages and a defense in foreclosure for violations of the Ability to Repay rules.

In this article, Amy Avitable, Director of Regulatory Compliance, TCS BaNCS discusses the following steps to mitigate risks when new mortgage reform rules will be implemented

  • Set your policy for making qualified mortgages and apply it consistently
  • Consider the consequences of how your qualified mortgage policy will apply
  • Determine whether your institution will make higher priced covered transactions
  • Consider adding residual income as an underwriting factor
  • Critically evaluate your record keeping
  • Eliminate prepayment penalties on mortgage loans
  • Review your home equity line of credit early termination or discharge fee
  • Leverage existing processes

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