MBA Letter to Members on Obama Regulatory Reform Proposal
June 17, 2009
"...The proposal is wide-ranging
and will have significant impact on the mortgage industry....
Link to:
MBA Reaction to Proposal
Summary of Proposal
Proposal
Text-85 pgs
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1st Quarter MBA National Delinquency Survey
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MBA NDS
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Save the Date
VMBA Summer Gala at the Burlington Boathouse
Wednesday,
August 5th
5:00 - 7:30
Two Winners of Three Red Sox Tickets each will be drawn at the Gala. Purchase Raffle Tickets Online Now
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Showcasing our Legal Community
Members
Coombs, Davis & Hill
Law Office of Fred V. Peet
Ward & Babb
Wick & Maddocks Law Offices
Wiener & Gale
Vermont Attorney's Title Corporation
Title Insurance Group of Chicago, Lawyers and Commonwealth
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Thanks to our
Attorney and Title
Insurance
Affiliate Members for your support.
Please Support those who Support us!
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All Member Employees are Welcome!
Please be sure all who would benefit from our news receive this newsletter.
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Are you Ready?
It's Time to Prepare, Plan, and Stay Informed.
Significant changes
affecting the mortgage lending industry will soon be effective both on the State and Federal level.
On May 21, Governor Douglas signed into law critical
legislation, H-171. These new requirements will drive much of the VMBA educational program content going forward.
VMBA will work to bring the information you need to understand and comply with these new rules.
Diane Smith Executive Director Vermont Mortgage Bankers Association |
Key Points of H-171 (SAFE Act):- All Vermont State
Licensed Lenders and Brokers must complete 20 hours of NMLS Approved
Pre-licensure Education and Tests by
July 1, 2010
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Pre-Licensing
requires 20 hours education including:
- 3 hrs Federal Law & Regulation
- 3 hrs Ethics, including fraud,
consumer protection, and fair lending
- 2 hrs Lending standards for
nontraditional mortgage products
- 12 hours Other Approved NMLS
courses
Individual Test fees: $92 National component + $69 VT = $161
I nitial Lending Licenses
must be obtained by July 1, 2010. All
applicants must pass the Federal and Vermont
tests, and successfully complete the PE education.
Current Licensed Lenders and Brokers - you have until December 1, 2009
to meet the Bond and liquid asset requirements of the new revisions to 8 VSA
2203.
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What's Next?
After you have met the requirements of the initial VT Lending License, the following is required annually, prior to December 1, when a renewal of the VT Lending License is due.
Annually Licensed Lenders must successfully complete:
- 8 Hours Continuing
Education Annually:
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3 hrs Federal Law & Regulation
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2 hrs Ethics, including fraud,
consumer protection, and fair lending
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2 hrs Lending standards for
nontraditional mortgage products
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1 hour Other Approved NMLS courses
Beginning in 2011, VT License renewal required on or before
December 1 annually requires the above CE.
Annual Continuing Education classes will count
only in the calendar year in which they are taken.
The same CE class may not be taken two years in
a row.
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These changes affect VMBA as well,
and we also are preparing for our future.
Our primary mission is to provide quality education to our members close
to home, and we expect to be ready to continue to do this for you. Essentially VMBA is:
- Preparing
to apply for approval by NMLS as an Approved Provider of Educational
classes
- Preparing
a series of classes to submit to NMLS for Approval as Pre-Licensure
Educational credits (PE credits)
Our
anticipated schedule of NMLS
Approved Pre-Licensure Education is:
- September
- 4 hours Federal Law
- October
- 6 hour program (two sessions) 4
hours State Law - VT Test Preparation (Elective credit), 2 Hours Reverse Mortgage (Nontraditional
credit),
- November - 3 hours
Ethics credit - Credit Bureau and FHA Fraud Prevention
Total Credits expected to be
offered by VMBA in VT before December is 13.
If approved as outlined, these classes will satisfy the required
classes for Pre-Licensure. Twenty credits
are required by July 1, 2010. We
anticipate the remaining 7 hours (Elective Credits) will be offered by VMBA
through the winter.
In addition to making plans for
VMBA to offer the initial licensing classes and the continuing education
classes, your Board of Governors is considering a proposal to form a New England regional MBA.
Regardless of the outcome of merger discussions, we anticipate
continuing to work with our New England
neighbor MBA's to partner with classes as appropriate.
At this time, I need to hear
from our Members. The mandatory
Education for Licensing changes the dynamics for VMBA, and makes it difficult
to plan on attendance. If a
representative from each of our lender members would email an estimate for
your company the number would likely register for the above programs. This is not binding - just an
estimate. However with so many of you
required to take classes, yet a lot of providers competing to provide the
credits, it's hard to know what size facility to reserve.
Please know that VMBA will incur
significant additional costs in getting our classes approved for Licensing
Education. However, we'll work to keep our costs as low as possible.
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MBA SUMMARY
HMDA Changes Take Effect July 30
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Summary - Federal Reserve Rule Implementing
Mortgage Disclosure Improvement Act of 2008, as amended
74 FR 23289; May 21, 2009
Background - This final rule
published by the Board of Governors of the Federal Reserve (Board) on May 19,
2009 amends Regulation Z (Truth in Lending) to implement the Mortgage
Disclosure Improvement Act (MDIA), as amended.1
Overview - (1) Extends the
requirement for transaction-specific good faith estimate or early TILA
disclosures that include, for example, the amount financed and the Annual
Percentage Rate (APR), to all dwelling-secured credit transactions except Home
Equity Lines of Credit (HELOCs); (2) Establishes waiting periods between the
time when disclosures are given to consumers and consummation or closing of the
transaction; and (3) Establishes procedures for consumers to waive or shorten
such periods based upon a bona fide financial emergency.
Effective Date - Becomes effective on
July 30, 2009, two months before the Board's pending regulatory changes to its
TILA/Home Ownership and Equity Protection Act (HOEPA) rules which become
effective October 1. MDIA also includes provisions requiring additional
disclosure language for adjustable loans but these provisions will be
implemented later.
CampusMBA & VMBA Co-Sponsor
New
TILA Requirements - Live Online Workshop 1st offering on June 23, 2009 AND "Encore" Mid-July
2:00 p.m. - 3:30 p.m. Call CampusMBA to Register a site at 1-800-793-6222, select option 3 between 9:00 and 5:00 Monday through Friday. Save the Date!
Wednesday, Sept 9, 2009 RESPA Update
Ruth Dillingham, First American Title
Burlington.
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Raise your Voice
Our industry is dealing with challenges created by HVCC - the Home Valuation Code of Conduct.
Link here to a Special Announcement from the Mortgage Market Guide, brought to us by one of our lender members.
For more information and links on the HVCC, go to our Spring Newsletter, posted on our Vermontmba.org website.
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VMBA 2009 Golf Open
A great success!
Check out the Photo's posted on our Website!
What a beautiful day we were rewarded with thanks to Rocky Ridge's offer to move the date a week for us.
Following were the winners this year -
congratulations to you all!
Putting Contest - Kevin Shortell
Closest to the Pin - Tom Connors
Men's Longest Drive - Nick Antell
Women's Longest Drive - Jessie Cook
1st Place Gross Score AND 1st Place Net Score -
Greg Hahr, Paul Hill, Steve Laquerre & Ed Levite
2nd Place Net Score - Dave Adams, Patti Brosseau,
John Hood & Rob Wheeler
3rd Place Net Score - Ande Deforge, JJ Hamilton,
Henry Rackliff & Steven Roberts
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Diane Smith
Executive Director
Vermont Mortgage Bankers Association
866-680-8622
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