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RESPA News Monthly <br> April 2012

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RESPA News Monthly
April 2012
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This month, find out how to keep your affinity relationships RESPA compliant. Also this month, RESPA News reported on new proposed rules the Consumer Financial Protection Bureau plans to release this summer and new CFPB interpretations published in April. RESPA News reported on industry associations’ reactions to the final mortgage disclosure form prototypes and rules the CFPB is considering. We also took a look at a bill that could remove home warranties from the settlement services definition under RESPA. In April, RESPA News reviewed RESPA in the courts and analyzed whether the new mortgage disclosure forms will help prevent fraud. In addition, RESPA New provided you with informative RESPA tips. Be sure to check out the April 2012 issue for these articles and more.



 
“When a loan originator permits a borrower to shop for third-party settlement services, the loan originator must provide the borrower with a written list of settlement services providers at the time of the GFE, on a separate sheet of paper.”
Posted Date: Thursday, April 26, 2012

 
Housing starts down, building permits up
Posted Date: Thursday, April 26, 2012
A Freddie Mac report showed that March was a mixed bag for the housing market. Residential housing starts were down drastically, while the number of building permits went up. Read on to find out what else the report showed.

 
Poll respondents share Section 8 interpretations
Posted Date: Thursday, April 26, 2012
RESPA News ran a poll in April asking readers if they thought the language in RESPA Section 8(b) prohibits unearned, undivided fees. Read on to find out what voters said.

 
Underwriters win lawsuit but remain at risk
Posted Date: Thursday, April 26, 2012
A homeowner sued two underwriters, alleging they overcharged her for title insurance when she refinanced her home, deviating from the state-approved rates. She argued that the underwriters’ actions were in violation of RESPA. The underwriters successfully argued the case should be dismissed. Even after dismissal, however, they remained at risk for another lawsuit on the same claims.

 
Will the new disclosures prevent fraud?
Posted Date: Thursday, April 26, 2012
The Consumer Financial Protection Bureau said its proposed integrated mortgage disclosure forms will be released this summer. After reviewing iteration after iteration of the prototypes, you may be wondering how the new forms will benefit consumers. A recent survey questioned whether the new forms could help reduce fraud. Read on to find out what the survey respondents and a panel of experts had to say.

 
Keynotes share a glimpse of what to expect in 2012 Summit addresses - Free Article
Posted Date: Monday, April 23, 2012
October Research has selected two very prominent figures to deliver the keynote addresses at the 2012 National Settlement Services and Compliance Summit. Read on for details of what they plan to share with attendees.

 
Associations support CFPB’s proposed privileged information rule
Posted Date: Monday, April 23, 2012
A group of industry associations wrote a letter to the Consumer Financial Protection Bureau indicating that they support a proposed rule that states information provided to the bureau during the supervisory process will not lose privileged status.

 
Associations to CFPB: Leave tolerance levels alone
Posted Date: Monday, April 23, 2012
In a letter to the Consumer Financial Protection Bureau, a group of industry associations requested the bureau leave tolerance levels alone. The CFPB wrote in a recent memorandum that it is considering tightening tolerance levels and listed other changes it is considering. Read on to find out what else the associations had to say to the bureau.

 
Keep your affinity relationship RESPA compliant – Part 3
Posted Date: Monday, April 23, 2012
If you are thinking about forming an affinity relationship, it’s important to decide which relationship is right for you. It’s also important to recognize that once you’ve formed that relationship, you need to stay compliant under federal consumer protection laws. In part three of this three-part series, RESPA News summarizes the compliance concerns associated with leads, workshare and technology agreements. Read on to find out how to have an affinity relationship and stay RESPA complaint.

 
SAFE Act allows transitional licenses
Posted Date: Monday, April 23, 2012
The SAFE Act, which requires loan originators to be registered nationally and in some cases licensed, allows states to provide transitional licenses for loan originators who are working outside of their home state. Read on to find out what the Consumer Financial Protection Bureau said about state reciprocity and transitional licenses.

 
“The special information booklet does not need to be provided if the loan originator declines the application or the applicant withdraws the application within the three business day period.”
Posted Date: Thursday, April 19, 2012

 
Association asks CFPB to use old HUD-1 formatting
Posted Date: Wednesday, April 18, 2012
Industry associations are working fast to submit their comments to the Consumer Financial Protection Bureau regarding the integrated mortgaged disclosure forms. One association suggests that the bureau can significantly cut the implementation time for the new forms by going back to the pre-2008 HUD-1 format.

 
Industry CEO: Disclosure forms impossible unless changes made
Posted Date: Wednesday, April 18, 2012
An industry executive wrote a letter to the Consumer Financial Protection Bureau suggesting that the new integrated mortgage disclosure forms will be impossible to implement unless the bureau harmonizes the Truth in Lending Act and RESPA regulations.

 
Keep your affinity relationship RESPA compliant – Part 2
Posted Date: Wednesday, April 18, 2012
If you are thinking about forming an affinity relationship, it’s important to decide which relationship is right for you. It’s also important to recognize that once you’ve formed that relationship, you need to stay compliant under federal consumer protection laws. In part two of this three-part series, RESPA News summarizes the compliance concerns associated with marketing service agreements. Read on to find out how to have an affinity relationship and stay RESPA complaint.

 
HUD disciplines loan officers and title agent for mortgage fraud
Posted Date: Tuesday, April 17, 2012
After three mortgage loan officers and a title agent were convicted for defrauding borrowers, lenders and the Federal Housing Administration, the U.S. Department of Housing and Urban Development banned the individuals from conducting business with the federal government.

 
Borrower sues home warranty company, alleges illegal referral fee
Posted Date: Monday, April 16, 2012
A homeowner sued a home warranty company, claiming that the company paid brokers an illegal referral fee in violation of RESPA. The company argued that it only paid fees for compensable services, which is allowed under RESPA. Read on to find out what the court said when the homeowner filed for class certification.

 
Borrower claims servicer violated Dodd-Frank Act
Posted Date: Monday, April 16, 2012
A borrower sued his mortgage loan servicer, claiming the servicer failed to reply to his qualified written request. The borrower relied on the new shortened time limits under the Dodd-Frank Wall Street Reform and Consumer Protection Act, which require a servicer to acknowledge a QWR within five days of receipt.

 
Banks held liable for service providers’ actions
Posted Date: Monday, April 16, 2012
The Consumer Financial Protection Bureau says it will hold supervised banks and nonbanks liable for the actions of service providers they contract with. The CFPB made it clear that outsourcing company functions to outside service providers will not get supervised institutions off the hook if that service provider violates federal consumer protection laws. Read on to find out what the bureau expects from the institutions it supervises.

 
Energy-related ownership rights becoming big issue for title industry
Posted Date: Monday, April 16, 2012
The recent movement for clean energy and onshore drilling is making it more and more difficult for title insurance professionals, who need to adapt both in the way they search for ownership on property and the way they insure that ownership. Read on for details about an educational event that will provide instruction on how to conduct better transactions with these unique and, many times, difficult properties.

 
Federal Circuit Court reviews ‘thing of value’
Posted Date: Monday, April 16, 2012
A federal appeals court reviewed two borrowers’ claims that their lender and appraisal provider violated Sections 8(a) and (b) of RESPA by paying kickbacks for referrals and splitting fees. The district court dismissed the claims, finding the borrowers failed to show a thing of value was exchanged for a referral and failed to allege unlawful fee splitting occurred. Read on to get the facts of the case and find out what the appeals court decided.

 
“The loan originator is not required to issue a GFE if, before the end of the three business day period, the loan originator denies the application or the loan applicant withdraws the application.”
Posted Date: Thursday, April 12, 2012

 
Cordray told to keep costs down
Posted Date: Wednesday, April 11, 2012
In a letter to Consumer Financial Protection Director Richard Cordray, two top U.S. House Republicans asked for assurances that the bureau will conduct cost-benefit analysis to ensure that new rulemakings are not a burden to the American people.

 
Consumer mortgage complaints focus on payment issues
Posted Date: Wednesday, April 11, 2012
The Consumer Financial Protection Bureau released a report indicating that consumer complaints the CFPB has received so far focus on payment issues. The bureau also described its complaint intake process and consumer reactions to companies’ efforts to resolve issues.

 
QWR rules coming this summer
Posted Date: Wednesday, April 11, 2012
You knew they were coming. Since the passage of the Dodd-Frank Act, it was only a matter of time until the Consumer Financial Protection Bureau drafted rules to shorten qualified written request timeframes and increase force-placed insurance regulation. That time has finally come. Read on to find out when the new rules will be released and what will be included in them.

 
Servicer hit with default judgment on RESPA claims
Posted Date: Wednesday, April 11, 2012
A residential mortgage loan servicer failed to file a response to a borrower’s lawsuit claiming the servicer violated RESPA. The borrower claimed that the servicer did not respond to her qualified written request as required under RESPA. When the servicer failed to respond, the borrower filed a motion for default judgment. The court agreed that the servicer violated RESPA and granted the motion for summary judgment in part.

 
Creditor sued for sale of mortgage that it says never happened
Posted Date: Friday, April 6, 2012
Two borrowers sued the owner of their mortgage claiming the creditor had violated the Truth in Lending Act by failing to provide them notice that the mortgage had been sold to it. The creditor filed a motion to dismiss, arguing that it had always been the owner of the note so no notice was required. The court denied the motion to dismiss, finding that the mortgage documents the creditor provided were not sufficient to contradict the borrowers’ allegations. Read on to find out the facts of the case.

 
Court says servicer’s response to QWR not good enough
Posted Date: Friday, April 6, 2012
A federal district court found that a mortgage loan servicer’s response to two borrowers’ qualified written request was not adequate under RESPA. Read on to find out the facts of the case and why the court found the servicer’s response lacking.

 
CFPB provides guidance on controversial LO comp. rule
Posted Date: Friday, April 6, 2012
In response to several questions about the Federal Reserve’s loan originator compensation rules, the Consumer Financial Protection Bureau published guidance explaining how the rules relate to certain qualified compensation plans. Read on to find out more.

 
Keep your affinity relationship RESPA compliant – Part 1
Posted Date: Thursday, April 5, 2012
If you are thinking about forming an affinity relationship, it’s important to decide which relationship is right for you. It’s also important to recognize that once you’ve formed that relationship, you need to stay compliant under federal consumer protection laws. In part one of this three-part series, RESPA News summarizes the compliance concerns with affiliated business arrangements. Read on to find out how to have an affinity relationship and stay RESPA complaint.

 
“If a borrower does not express an intent to continue with an application within ten business days after the GFE is provided (or such longer time period specified by the loan originator), the loan originator is no longer bound by the GFE.”
Posted Date: Thursday, April 5, 2012

 
CFPB promotes financial literacy month
Posted Date: Thursday, April 5, 2012
April is financial literacy month, and the Consumer Financial Protection Bureau says it’s teaming up with other government agencies and businesses to promote financial literacy. The bureau says it plans to provide financial tips and facts for consumers throughout the month.

 
RESPA home warranty bill continues to gain momentum
Posted Date: Thursday, April 5, 2012
The inclusion of home warranties as settlement services regulated under RESPA has been highly debated in the industry. Some argue that home warranties should not be regulated under RESPA. Others simply say that because home warranties are specifically included in Regulation X, they are subject to RESPA. A bill currently in the U.S. House of Representatives can put an end to this controversy. Read on to find out more about the bill, and its recent movement.

 
RESPRO Coverage: RESPA in the courts – Part 3
Posted Date: Thursday, April 5, 2012
In part three of this three-part series, RESPA News reviews an important affiliated business arrangement case currently in the U.S. 6th Circuit Court of Appeals and the relationship between class action certification and RESPA.

 
Court finds argument for class action compelling
Posted Date: Thursday, April 5, 2012
In a RESPA action, a federal district court indicated that the plaintiffs had a compelling argument for class certification. Read on to find out why the plaintiffs are suing and who the proposed class would include.

 
Court finds creditor vicariously liable for servicer's TILA violation
Posted Date: Tuesday, April 3, 2012
A federal district court found that a residential mortgage loan creditor was vicariously liable for the loan servicer’s Truth in Lending Act violation. Read on to find out the facts of the case.

 
Cordray plans to crack down on cheaters
Posted Date: Monday, April 2, 2012
In a speech to the U.S. Chamber of Commerce, Consumer Financial Protection Bureau Director Richard Cordray told the group that “upstanding businesses will benefit the most when those that cheat their customers are held accountable.” Read on to find out what else Cordray had to say.

 
Federal district court strikes down lenders’ removal of RESPA action
Posted Date: Monday, April 2, 2012
A federal district court remanded a RESPA action to state court finding that the lender defendants filed the notice of removal too late. The defendants argued that the case could not be removed earlier because the first federal question appeared in the amended complaint, not the original. Read on to find out why the court said the defendants were wrong.

 
RESPRO Coverage: RESPA in the courts – Part 2
Posted Date: Monday, April 2, 2012
In part two of this three part series, RESPA News reviews Freeman v. Quicken Loans, a case currently before the U.S. Supreme Court. Read on to find out why attorney Jay Varon says this case could benefit the industry and possibly get rid of many RESPA cases currently in the courts.

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12 USC Section 2605 or Section 6 is titled Servicing of mortgage loans and administration of escrow accounts. It pertains to qualified written requests, notices of transfer of servicing and the administration of escrow accounts.
An arrangement that involves a person who is in a position to refer business as part of a real estate settlement service and who has an interest in a settlement services provider.

In the arrangement, the person, who has either an affiliate relationship with or a direct or beneficial ownership interest of more than one percent in a settlement services provider, directly or indirectly refers business to that provider or influences a consumer to select that provider.
An arrangement that involves a person who is in a position to refer business as part of a real estate settlement service and who has an interest in a settlement services provider.

In the arrangement, the person, who has either an affiliate relationship with or a direct or beneficial ownership interest of more than one percent in a settlement services provider, directly or indirectly refers business to that provider or influences a consumer to select that provider.
A mortgage disclosure that lists all estimated charges and fees associated with your loan. In addition to fees and charges, it will list your loan amount, mortgage rate, loan term and estimated monthly payment. Your escrows due at closing for insurance and taxes will also be outlined. Mortgage lenders are legally required to provide a GFE within three days of receiving your application.
A mortgage disclosure that lists all estimated charges and fees associated with your loan. In addition to fees and charges, it will list your loan amount, mortgage rate, loan term and estimated monthly payment. Your escrows due at closing for insurance and taxes will also be outlined. Mortgage lenders are legally required to provide a GFE within three days of receiving your application.
Under RESPA Section 2605(e)(1)(B), a qualified written request is a written correspondence that includes: 1) the name and account of the borrower, or has enough information to allow the servicer identify that information; and 2) a statement of the reasons for the belief of the borrower that the account is in error or provides sufficient detail to the servicer regarding other information sought by the borrower.

A QWR cannot be written on a payment coupon or other payment medium supplied by the servicer.
Under RESPA Section 2605(e)(1)(B), a qualified written request is a written correspondence that includes: 1) the name and account of the borrower, or has enough information to allow the servicer identify that information; and 2) a statement of the reasons for the belief of the borrower that the account is in error or provides sufficient detail to the servicer regarding other information sought by the borrower.

A QWR cannot be written on a payment coupon or other payment medium supplied by the servicer.
12 USC Section 2609 or Section 10 is titled Limitation on requirement of advance deposits in escrow accounts. It governs escrow accounts including notifications and statements to borrowers. Section 10 also sets out penalties for those who violate the section.
RESPA Section 3 provides that a thing of value includes any payment, advance, funds, loan, service or other consideration

Regulation X says thing of value includes: monies, things, discounts, salaries, commissions, fees, duplicate payments of a charge, stock, dividends, distributions of partnership profits, franchise royalties, credits representing monies that may be paid at a future date, the opportunity to participate in a money-making program, retained or increased earnings, increased equity in a parent or subsidiary entity, special bank deposits or accounts, special or unusual banking terms, services of all types at special or free rates, sales or rentals at special prices or rates, lease or rental payments based in whole or in part on the amount of business referred, trips and payment of another person’s expenses or reduction in credit against an existing obligation.
A form used by a settlement or closing agent itemizing all charges imposed on a borrower and seller in a real estate transaction. This form represents the closing transaction and provides each party with a complete list of incoming and outgoing funds. RESPA requires the HUD-1 to be used as the standard real estate settlement form in all transactions in the U.S. involving federally related mortgage loans.
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