Here’s the follow up from Friday’s class.
Q: Where can I get more info on the liability of originating QMs v. non-QMs?
A: Here is the CFPB Compliance Guide. Go to page 26 for the Safe Harbor explanation on the two types of QMs, regular and higher priced.
Lenders are strongly dis-incentivized to originate non-QMs in the new rule though the reports and articles I’m reading don’t specifically state that our liability is higher when we originate non-QMs it is implied everywhere. This article in the WSJ gives some insight.
Here is a link to the CFPB Consumer Compliant database. There’s a menu running across the page, not at the top but near the top. It’s inside a gray table. It says “Data By Product.” For the dbase we played around with, click on “mortgages”
There was a request for NACA’s default rate. Although there are many articles all over the web quoting their low default rate, I can’t find one source for it on their website. The event I attended had several NACA reps there and they answered my question live. Here is the article I wrote for anyone who did not have a chance to read it.
Q: Can mortgage brokers pay their LOs commission under the new LO Comp plan coming in 2014?
A: Here is the CFPB compliance guide. Go to the bottom of page 4. The old FRB rules on LO comp from 2011 are still in place—no steering consumers into lesser-quality loans or steering consumers to loans only to be given higher compensation (the old YSP or overage.) <–All of that is still prohibited.
RE the Shawn Portmann case, I had thought the FDIC was going after PC bank’s board but I was wrong….Instead the FDIC is going after the executives from CityBank in Lynnwood, one of Shawn’s former employers before he went on down to Tacoma.