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Vermont Extends Suspension of High-Rate Disclosure Requirement

Under Title 9, Section 104 of the Vermont Statutes Annotated, the Vermont Commissioner of Financial Regulation (the “Commissioner”), adopted Regulation B-98-2, which adds a disclosure requirement for a first-lien loan when a borrower is expected to be charged (1) interest in excess of three percent over a rate established pursuant to 32 V.S.A. § 3108 (the “Declared Rate”) or (2) over four points in closing costs.   

CFPB Issues Amendment to Data Reporting Thresholds Under HMDA

On December 21, 2022, the Consumer Financial Protection Bureau (“CFPB”) published technical amendments to Regulation C in the Federal Register.  The amendments to Regulation C §§ 1003.2 and 1003.3, along with related comments in Supplement I to Part 1003 of Regulation C, provide that the reporting threshold for closed-end mortgage loans has been decreased from 100 loans to 25 loans in each of the prior two calendar years.  The new threshold fo

Revised Timeline: FHA/VA Instrument Updates

As noted in prior articles, Fannie Mae and Freddie Mac published new versions of their Uniform Instruments in July 2021, with a required use date as of January 1, 2023.  DocMagic moved to the new versions of standard conventional documents as of August 12, 2022.  DocMagic previously announced we would be making updates to the notes and security instruments used for FHA and VA loan types as a result of these changes.  

New York Subprime Index Updated

New York Banking Law Section 6-m(1)(c)(ii) identifies the FreddieMac Primary Mortgage Market Survey (“PMMS”) as the threshold for determining the calculations for defining a “subprime home loan.”  Beginning with the November 17th publication of the PMMS, Freddie Mac announced it would no longer publish the 5/1 ARM rate, which is used in the New York Subprime Audit for ARM loans with an adjustment period of at least 3 years.  On December 20th, the NY Department of Financial Services

CFPB Annual Threshold Adjustments for Regulation Z

The Consumer Financial Protection Bureau (“CFPB”) is required to calculate annually the dollar amounts for several provisions in Regulation Z.  The CFPB recently issued a final rule amending the dollar amount thresholds under the HOEPA “points and fees” provisions of Regulation Z (12 CFR § 1026.32)(a)(1)(ii)) , referred to as “Section 32” by the industry, and the qu

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