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The Dodd-Frank Act created a new world for mortgage servicing. While most lenders have incorporated the changes and continue to monitor the high-risk areas of real estate lending, there is an unexpected shift in the landscape. Suddenly, the mortgage insurance aspect of lending has made new headlines. A dispute over a PMI violation resulted in a $100 million dollar fine that prompted the eventual court decision that the CFPB’s structure is unconstitutional. Now, President Trump has canceled a last-minute reduction in mortgage insurance premiums on loans backed by the FHA, and PMI continues to be a high-value target of examination, complaints, and litigation. Recent CFPB guidance and enforcement actions have shed new light on the expectations of the regulators. Is your institution prepared for the increased focus?
PMI is arranged by the lender for your protection and is provided by private insurance companies. The CFPB has gone to great lengths to recognize the good and bad within the PMI area. Like other kinds of mortgage insurance, PMI can help borrowers qualify for a loan that they might not get otherwise. But, it increases the cost of the loan and it doesn’t protect them from problems. In some situations, the lender may not cancel the insurance when required or delay when a borrower requests cancellation. That is where the CFPB plans to act.
The Homeowners Protection Act of 1998 (HOPA) provides additional homeowner protection when cancelling PMI. Until now, it has been a relatively quiet compliance area. From inadequate settlement disclosures to faulty termination processes, the CFPB has been actively pursuing enforcement. This webinar will provide a full review of PMI and HOPA requirements and will focus on the unique compliance challenges presented by CFPB’s recent guidance and enforcement actions.
HIGHLIGHTS
Best practices to manage PMI problems
Understanding PMI compliance requirements
Focus on termination and disclosure requirements
Interplay with other real estate lending regulations
Interpreting the recent CFPB PMI termination guidance
Analysis of recent litigation and enforcement actions
TAKE-AWAY TOOLKIT
PMI examination guidance
PMI risk assessment guidance
Employee training log
Quiz you can administer to measure staff learning and a separate answer key
Attendance verification for CE credits provided upon request.
WHO SHOULD ATTEND? Chief Credit Officers, executives, senior management, audit committee members, and staff involved with compliance, real estate lending, collections, internal audit, and real estate lending and loan servicing.
ABOUT THE PRESENTER – David A. Reed, Reed & Jolly, PLLC, Attorney, author, consultant, and nationally-recognized speaker. He provides guidance to financial institutions on establishment and revision of policies and procedures, organizational compliance, collections, security, contractual agreements, regulatory matters, and corporate governance. His engaging speaking style has made him a nationwide lecturer on regulatory compliance, consumer lending, bankruptcy, and collections. A former trial attorney and vice president and general counsel of a large credit union, David is particularly known as an expert in the areas of operations, bankruptcy, and collections. He has trained state and federal examination staff on numerous issues, including BSA, ID theft red flags, SAFE Act, third-party contract management, and bankruptcy. He also serves as editor of several industry manuals.
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