Calendar of Events

Untangling the Web of Fee Disclosures

11/06/2017, 1:30 PM to 3:30 PM

No location provided

Amy Davis adavis@msbankers.com 601-948-6366

Description:

Untangling the Web of Fee Disclosures

 
Presented by Jack Holzknecht and Kelly M. Owsley
Monday, November 6th, 2017
1:00 pm - 3:00 pm CT
 

Program Content:

Upon completion of the program, participants understand that improper fee disclosure may result in violations. In some cases a violation of one section may result in one or more violations of other sections. It is a tangled web. For example:
  • A violation of the finance charge rules contained in §1026.4 may also cause a violation of the disclosure requirements in §1026.18 or §1026.38 since the finance charge is included in those disclosures;
  • Improper categorization of fees on the TRID disclosures contained in §1026.37 and .38 may result in a violation of the tolerance rules contained in §1026.19;
  • Failure to follow the APR calculation rules contained in §1026.22 may result in:
    • The incorrect APR appearing in the disclosures contained in §1026.18, §1026.32, §1026.37 or §1026.38;
    • Inadvertently triggering coverage of §1026.32;
    • An inaccurate calculation of the rate spread disclosed on the HMDA LAR and used to determine the applicability of the high-cost mortgage loan rules contained in §1026.32 and the higher-priced mortgage loan rules contained in §1026.35; or
    • The incorrect disclosure of the HOEPA status disclosed on the HMDA LAR;
    • An inaccurate determination of the higher-priced covered transaction status of a loan for purpose of determining which a transaction achieves safe harbor or presumption of compliance status for the ability to repay rules in Section 1026.43;
  • Failure to properly calculate the total points and fees as prescribed by the high-cost mortgage loan rules contained in §1026.32 can:
    • Inadvertently trigger §1026.32 coverage;
    • Violate the disclosure rules contained in §1026.32;
    • Result in an incorrect entry on the HMDA LAR; and
    • Blow the Qualified Mortgage status for purposes of §1026. 43; or
  • Failure to follow TRID rules contained in §1026.38 may result in the incorrect disclosure of the total of all itemized amounts that are designated borrower-paid at or before closing on HMDA LAR.
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