March 6, 2014 - IMMAAG encourages state licensed MLO's to sit for Stand Alone Uniform State Test. In an email to its registered users IMMAAG today offered arguments for sitting for the 25 question stadn alone uniform state test offered by the owners of teh NMLS. To help prepare for the test here are a few links:
Link to prep course ($79, 15 pages) available at Real Estate Institute - click here.
Want to avoid any cost, but do more reading? Here are the three referecne sources on which the test questions are based:
Link to the SAFE Act (free, 21 pages) - click here.
Link to Regulation H (free, 22 pages) - click here.
Link to the State Model Law (free, 16 pages) - click here.
February 2014 - IMMAAG's small shop MLOCompliance.com solution soft launches. Announced in two separate trade announcements, this affordable, targeted, comprehensive compliance managment system is designed to "Make Competing and Complinace Compatilbe. See details by clicking here. The 100 company founder group is filling up. Feel free to call Bill Kidwell at (303) 674-1200 to discuss its fit with your company.
November 26,2013 - FinCEN responds to IMMAAG's request for clarification about one-person MLO shops and independent audit requirements in the AML rule from August 2012. After a 14 month wait, FinCEN rules (unofficial, but written) that a one-person RMLO's must still comply with the requirement to have an "independent" AML test/audit function. So, whether you "barter" with another shop or pay a third party, if you are a one person shop you have to do something - you can not be both the Anti-Money Laundering Program Compliance Officer and the program's tester/auditor. Se a copy of FinCEN's response to IMMAAG by clicking here. For a summary of the FinCEN letter and copy of IMMAAG update sent to its users,click here.
August 9, 2013 - IMMAAG has posted a "script" for you to prepare for your August in district congressional visit. It is meant to help you stay laser focused on the issue during that visit. It is available by clicking here.
August 5, 2013 - Congressional Committe List and Sponsor list available - IMMAAG has added lists with the members of the House Financial Services Committee, the Senate Banking Committee and the Sponsors / Co-Sponsors of HR1077 and S949 to the "Call to Action" page for the August district visits. Click here to go to the action page and access the materials and documents.
August 1, 2013 - IMMAAG has posted a consolidated the "Congressional Visit Package" on the website. Click here for the package and a "Talking Points document. The "ala Carte" documents are still available on the same page. But, if you want to simply open and print the Cover Letter, The Congressional Package and the talking Points you will have a complete package, pre-pared to share with your Congressional member and Senator. The package also contains a state by state list (behind the Fact Sheet) of the number of companies and MLO's in each state so you can circle your state and make a point about how many small businesses and voters are damaged by the final rule. A summary document about what is "in and out" of the Points and Fees will be added on Friday, Augsut 2, 2013.
July 30, 2013 - SUPPORTING MATERIALS FOR AUGUST 2013 CALL TO ACTION STOP THE LO COMPENSATION POINTS AND FEES FINAL RULE!
Use this link to access all the information you need to make a difference in August
July 17, 2013 - Washington D.C. - President Obama once again singles out mortgage brokers - negatively. View the clip of his comment during the announcment of the confrimation of Richard Cordray as the CFPB's Director by clicking here. If you want to view the entire fifteen minutes of his remarks, click here.
May 29, 2013 - CFPB publishes the final Qualified Mortgage / Ability to Repay amendments and causes an immediate negative reaction by its disparate treatment of state licensed mortgage loan oirignators. IMMAAG will be offering additional details and actions the week of June 10th. In the meantime, access the final rule by clicking here.
May 3, 2013 - With more than 130 volunteers already on board, IMMAAG is pleased to announce the launch of the May 2013 "Early Disclosure Project". Materials supporting the intiative are available by clicking here or on the right side of this home page. If you are already a volunteer, thanks for your help. If you want to volunteer just get copies of the support materials and join the rest of us during the month of May. A 20 minute instructional webinar is available by clicking here. I encourage you to view it prior to conducting your surveys.
March 28, 2013 - CFPB publishes access to Consumer Complaint Data Base. In a press release today, the CFPB announced and summarized complaints it has collected for over a year. There have been over 100,000 complaints with 50% of them related to mortgages. IMMAAG shared a summary of the origiantion related complaints with its users. For more on the CFPB's data:
> Click here to read the text of the Annual Report to Congress
> Click here to read a 15 page fact sheet about the complaints
> Click here to access an alpha-sorted list of the 221 companies with origination complaints
> Click here to access the 221 company list sorted from high to low count.
February 25, 2013 - IMMAAG's final ATR/QM comments posted. Full text available by clicking here
February 23, 2013 - IMMAAG adds Comments for Consideration. Click here (we've prepared some thoughts for you to consider) if you are having trouble drafting comments to share with the CFPB about the proposed changes to its final ATR/QM rule. Remember that public comments are due by Monday, 2/25/13.
Click here to go directly to the comment input page when you're ready
February 19, 2013 - IMMAAG alerts users to CFPB - ATR/QM Proposal comment period end date of February 25, 2013 and encourages comments on Points and Fees proposal.
Click here to access the six page highlighted excerpt of the Points and Fees section of the proposal
Click here to access the 52 page text of the Bureau's concurrent ATR/QM proposal
Click here to access the full text of the FINAL ATR/AM Rule published January 30, 2013
CLICK HERE to go directly to Regulations.gov to input and/or upload your comment!
February 13, 2013 - IMMAAG prepares for February 25th CFPB Concurrent Proposal Comments. In an alert to all of its users and subscribers IMMAAG announced it will have more comprehensive information to assist everyone in preparing comments due 2/25/13 to the CFPB by February 18th. In order to assist its users in preparing IMMAAG has posted links to several key items:
Click here to access a pagenated Table of Contents to the entire 52 page proposed rule.
Click here to access the rule in its full text (78FR6622, January 30, 2013)
Click here to access a highlighted, edited excerpt of the pages relating to the Points and Fees issue.
January 18, 2013 - CFPB Announces final LO Compensation Rule, publishes four page summary (full text of the summary is available by clicking here) and announces the full final rule will be available at http://www.consumerfinance.gov/regulations on Janaury 20, 2013.
January 10, 2013 - CFPB publishes 1,500+ pages of final rules and amendments to the final rules. In four different releases, the Bureau has given the mortgage industry significant homework. Today they issued final rules on Ability to Repay (full 804 pages of text available here) with an effective date of 1/10/2014; they also provided a 185 page proposed amendment to the Final Rule to allow public comment until 2/25/13 on certain exemptions and Loan Originator Compensation regarding Points and Fees (full text of the proposal is available here); a 431 page final rule on High-Cost Mortgage Homeownership Counseling for both Regulation Z and Regulation X (full text available here); and last but not least 116 pages in the final rule on Escrows for Higher-Priced Mortgages. (full text available here). IMMAAG encourages your attention to the request for public comment on the Ability to Repay rule.
January 8, 2013 - CFPB Announces 2013 Regulatory Agenda. The Bureau intends to finalize four proposed mortgage rules in January 2013 (LO comp, Mortgage Servicing, High Cost Escrow and Ability to Repay) while announcing the Integrated Dislcosure Rule will be finalized by September 2013. To read the entire 3 1/2 page announcement click here.
December 13, 2012 - CFPB offers everyone the chance to "Build Your Own Disclosures Trial Program" and be part of the solution! In a December 13th press release (available here) the Bureau announced a trial program that will offer selected companies that request to participate a chance to be exempt from current mortgage disclosures and to design and use their own disclosures. At the same time the Bureau issued a request for public comment (full text available here) about the program. IMMAAG will be evaluating the implications and sharing additional details in the near future.
November 6, 2012 - IMMAAG's comments on the CFPB Proposed Disclosures joins another 2,800+ commenters. The single largest industry group to send their thoughts appears to be the Title industry. IMMAAG's comments are available by clicking here.
November 5, 2012 - CFPB Proposed DISCLOSURE COMMENTS DUE TOMMORROW (11/6/12)! Excerpts of the 112 requested comments in the proposal are available for review by clicking here. The full 343 page proposal is available by going to regulations.gov and searching for CFPB-2012-0028.
October 5, 2012 - In an effort to help de-"mythify" the January 2013 Real Estate / Medicare Sales Sur-Tax IMMAAG is posting a link here to a ten page pamphlet produced by the National Association of Realtors. The panphlet explains in simple terms how the new tax on some investments, inlcuding capital gains may affect some people selling their primary residences. Click here to access the pamphlet. If you are not already in an adjusted gross income category above $200,000 (individuals) or $250,000 (married filing joint return) and don't do soemthing to create a capital gain that will take you above that level the 3.8% surtax will not apply to you.
September 12, 2012 - CFPB posts 25 member Consumer Advisory Board membership on the CFPB's website. To see the published charter, click here. To read the brief biographies of each member as published by the CFPB click here.
September 10, 2012 - LO Comp Comment Period Correction - Comments for the LO Comp Rule still due October 16, 2012. Want to make a comment? Click here to go to the Regulations.gov site.
September 10, 2012 - AML Program materials added for subscribers and donors - The checklists, process preview and quiz materials have been added to the subscriber area of the webiste. Subscribers and donors ($75 or more) may simply click here and log in to go to the links to all the AML Materials.
September 6, 2012 - CFPB extends finance charge comment period. On 9/6/12, the CFPB announced an extension of the period to comment on portions of the 1,099 page rule (only 343 pages as posted in the Federal Register on 8/23/12 - click here for the full text of that version) on disclosures which were originally due tomorrow. The action appears to be at least partially the result of August 30th comments submitted by the SBA Office of Advocacy. While the extension does not delay the closing date for comments solicited on coverage of the rule, it does allow more time for industry to consider and weigh in on the way the Bureau appears intent on dealing with what remains a convoluted and unnecessary complication of helping consumers understand the financial implications of their decision to finance a purchase or refinance a home. The full text of the SBA's letter is available here. The CFPB Extension posted in the Federal Register is available here. IMMAAG will comment on the coverage proposal by tomorrow and will offer thoughts on the finance charge proposal over the next few weeks. Both will be posted on the website.
August 16, 2012 (Updated 9/7/2012)- CFPB issues 369 page proposed Loan Originator rule which will affect Points and Fees and MLO Compensation. The unpublished document had a comment period closing date of October 16, 2012. The 100 PAGE version of the LO COMP RULE was finally PUBLISHED IN FEDERAL REGISTER 9/7/2012. Click here to access the full text of that rule. Comments are still due October 16, 2012 for everything except the Paperwork Reduction Act provisions which have been extended to November 6, 2012.
The Press Release is available here. The CFPB's six page summary is available by clicking here and the full text of the 369 page document is available by clicking here. There is also a 159 page report issued about the Small Business Panel that reviewed the items being considered in May 2012. That document is available here.
August 13, 2012 - IMMAAG offers Anti-money Laundering compliance solution free to subscribers. For information click here.
July 23, 2012 - NMLS data base must be updated by August 1, 2012. Companies and individuals registered with the NMLS have until August 1, 2012 to update data base information. Click here to access a Company "Quick Reference Guide" and click here to access an Individual "Quick Access Guide". For only a $75 payment to the SRR (that is the for-profit subsidiary of the CSBS that manages the NMLS) there is training available on July 25, 2012 from 2:00PM - 3:30PM (EDT). Click here to register. It was still open at 2:30PM (EDT) July 23, 2012. Do not know when it will close.
July 9, 2012 - CFPB has 107 comments to Ability to Repay posted and publishes an 1,100 page disclosure notice. Full text available here; IMMAAG comments and thoughts will be coming over the next few months. Stay tuned and if you are a registered user or subscriber you received our first thoughts July 10th.
July 9, 2012 - CFPB Comment period regarding Ability to Repay (includes Qualified Mortgage) ends July 9th. Read the full text of IMMAAG's comments by clicking here. To review the six page CFPB Federal Reserve announcement click here. To read and make use of IMMAAG's July 6th newsletter content to help you formulate your comments - and to share this with others, too; click here.
June 28, 2012 - Washington D.C. - Another House subcommittee hearing, this one on appraisals has no MLO representation. IMMAAG offered a statement for the record. Read the text of our statement here.
June 20, 2012 - Washington D.C. - House Subcommittee on Insurance, Housing and Community Opportunity to hear testimony from CFPB and Industry on mortgage disclosures. A live video feed at 1:30PM, Wednesday June 20th, 2012 is available by clicking here and going to the "Live Webcast" icon at the left bottom of the landing page. IMMAAG's written statement for the subcommittee record is available by clicking here.
May 23, 2012 - Washington D.C. Small Business Panel meets with industry Small Entity Representatives (SER's) to discuss the CFPB mortgage loan origination proposals. BE AFRAID ENOUGH TO ACT!
See the questions the CFPB asked for answers to by clicking here.
Read the IMMAAG update about the meeting and the actions you must take by clicking here.
Then if you care about your customers or your business - sign the petition to Amend Dodd Frank by clicking here.
May 16, 2012 - IMMAAG completes its summary of the May 9th CFPB Proposals Under Consideration and posts the summary and a comments document. To read the summary click here. To read IMMAAG's comments which offer a different approach than the CFPB is taking, click here. Then click here to go to the Petition to Amend teh Dodd Frank Act and join teh thousands who are signing and circulating it.
May 10, 2012 - Second year University of North Carolina law student says banning yield spread is the wrong way to go. Read her paper here.
May 10, 2012 - CFPB Issues its 37 page Small Business Panel Proposal & Considerations document. It provides insights into the CFPB's assessment of how it sees the implementation the Dodd Frank Act and MLO compensation among other things - read the full text here - then ACT! - sign the petition to amend the Dodd Frank Act here.
May 1, 2012 - IMMAAG's Dodd Frank Amendment Petition IS NOW AVAILABLE!
Use the linked photo to see a five minute video about the petition. Click here to read the background and amendments requested by the petition. Then click here to go to the petition site and sign the petition.
April 23, 2012 - IMMAAG recommends an alternative course to supporting HR 4323 - the Consumer Mortgage Choice Act. In an alert to its registered users on Monday, April 23d, IMMAAG provided an alternative to supporting yet another piecemealed, likely uneffective legislative proposal. While Points and Fees needs immediate correction, the bill falls short. IMMAAG offers a better solution.
Read the announcement and action item sent to users here.
Review the TILA Points and Fees Evolution here.
Get a copy of IMMAAG's draft Dodd Frank amendment here.
Find your representaive's contact information here.
April 2, 2012 - CFPB Clarifies LO Comp Rule allows paying originators in "Qualified Plans". Click here to read the entire text. Then send your operational issues to email@example.com, Subject: LO Comp Operational Clarity.
March 27, 2012 - FHA Seller Concession Comment period ends. Link to public comments here. Read IMMAAG's comments by clicking here.
March 13, 2012 - CFPB extends Regulatory Streamlining "comment on the comments" period until June 4, 2012. Read the announcment by clicking here.
March 12, 2012 - IMMAAG sends proof of consumer harm package to CFPB. In response to a request from Mr. Peter Carroll, the Bureau's senior Mortgage Markets manager, IMMAAG has shared information showing both anecdotally and empirically that the LO Comp Rule has harmed consumers. Details of the enitre package are available here.
For the text of the cover email to Mr. Carroll, click here.
To read the cover letter that explains the package, click here
For the complete, 3 section package including the April 2011 letter from IMMAAG, click here
To read Congressman Barney Frank's request for the Board to change the rule, click here.
March 6, 2012 - FHA issues Mortgagee Letter 2012-04, reduces UFMIP on streamline refinances effective in June 2012 and other MIP changes. Access the ML by clicking here.
March 5, 2012 - IMMAAG posts comments responsive to the CFPB request for information regarding regulatory streamling. Click here to read our submission to the Bureau.
February 20,2012 - Posted for 12/5/2011 - CFPB publishes request for information and public comment on streamlining inherited regulations - read the five page Federal Register posting by clicking here and join the IMMAAG initiative to comment by March 5, 2012. Click here to read IMMAAG's excerpts of the CFPB request.
February 1, 2012 - President Obama announces a new Home Owner Bill of Rights. He also shows the nation what looks like a new one page mortgage disclosure. A copy of the the three page prototype form from the CFPB can be viewed by clicking here. Click here to listen to President Obama's speech today. And, click here for a copy of the transcript. HUD Secretary Shaun Donovan offered more details on the new housing refinance program. Click here to see a short video interview with Secretary Donovan after the briefing.
IMMAAG thanks Jerry Ellsworth for sharing a more detailed copy of President Obama's Housing Plan. Click here to learn more.
January 26, 2012 - Your chance to interivew President Obama - click here to ask your question of the president for possilbe inlcusion in an interivew scheduled for Janaury 30, 2012. Questions must be asked by midnight EST, Saturday, January 28th, 2012.
January 4, 2012 - Shaker Heights, IL - President Obama exercises his presidential “authority" to “recess” appoint Richard Cordray as Director of the Bureau of Consumer Financial Protection. To watch the video of the announcement click here. The announcement begins at about 6 minutes and 40 seconds into the video. At about 8 minutes and 10 seconds and again at 12 minutes/40seconds Mr. Obama repeatedly singles out mortgage brokers as bad guys - Thanks Mr. President!
January 4, 2012 – WashingtonD.C. – Chairman Bernanke sends white paper revisiting recent housing history and making some suggestions to the House Financial Services Committee and Senate Baking Committee. Read the text of the 26 page white paper by clicking here.
December 19, 2011 – WashingtonD.C. – New tax Are your ready for a tax increase? Did you know about it? During the recent break-neck speed Congressional activities to keep the government running Dave Camp’s (R-CA-3) bill HR-3630 entitled Temporary Payroll Tax Cut Continuation Act of 2011 was passed. It includes a little known provision for new, incremental mortgage back security guarantee fees – but they are not guarantee fees and the process was hardly transparent. Take a look at the 3 page excerpt of the Guarantee Fee portion of the bill by clicking here. Check out the entire Payroll Tax Cut Continuation Act by clicking here. And, if you have not received your talking points and would like to say something to your representative about this little secret, send an email to firstname.lastname@example.org and we’ll send our information to you.
Washington D.C. - December 8, 2011 - Senate rejects cloture regarding nomination of Mr. Richard Cordray to assume control of the Bureau of Consumer Financial Protection. Get more information and see how your Senator voted by clicking here.
December 5, 2012 - IMMAAG makes available FREE NMLS CE's to registered users who support IMMAAG with a regular annual subscription. See details here.
November 10, 2011, West Palm Beach, FL - Software vendor OpenClose offers origination software for "untrained" mortgage originators based on requests from community banks and credit unions. Read the full release by clicking here. Then, please send us your thoughts about this "tool" to email@example.com.
House Financial Services Democrats plead with Senate Republicans - November 17, 2011 – Washington D.C. – All 27 Democrat members of the House Financial Services Committee signed a two page letter sent to Senator Mitch McConnell, Minority Leader, urging him to support the full Senate approval of Mr. Richard Cordray as Director of the Bureau. Click here to read the letter.
November 17, 2011 - Fannie and Freddie Publish HARP Guidelines - In a seven page bulletin Fannie Mae sent its sellers an explanation of what it will be doing to implement the extension of the HARP program announced by the Administration a few weeks ago. Freddie Mac followed suit with a five page update of its own. The Fannie Mae Bulletin is available here. Click here for the Freddie Mac bulletin.
November 8, 2011 - CFPB offers intitial drafts of new pre-closing disclosures required by the Dodd Frank Act. Go to the CFBP KnowBeforeYouOwe page and check out the forms, then pick the one you prefer. If you want to add comments send an email to firstname.lastname@example.org. And, we'd appreciate a cc to email@example.com.
November 7, 2011 - CFPB holds a 10 minute conference call to announce its new Enforcement Early Warning System. The press release is available here. The Bulletin can be read here.
November 2, 2011 - St. Charles, MO - IMMAAG joined industry professionals at MAMP's Annual Convention and had the opportunity to share time with Mr. James Fuchs of the St. Louis Fed and Mr. Mike Anderson, NAMB's Government Affairs Chairperson to update participants about legislative and regulatory issues and to enlist MAMP's members and other participants to join in the emerging grass roots effort to focus on leveraging the new Bureau and the Congress to work together, implement a study and then implement appropriate chages. IMMAAG thanks Dennis Tate and the other officers of MAMP for allowing us to share our views and ideas with the enthusiastic audience.
October 26, 2011 - IMMAAG requests that the Mortgage Licensing Policy Committee re-open and extend the comment period on a little known July 22, 2011 request for comments about State Regulator Action Reporting to the NMLS&R. You will be interested in the subject if you are a state licensed mortgage loan originator and were unaware of the proposal and request for comments.
October 2011 - CSBS/AARMR's Multistate Mortgage Committee (MMC) issues examiner manual and guidance for state examiners to use to conduct compliance reviews on mortgage companies and the loan originator compensation rule.
Click here to access the 263 page Mortgage Examiner Manual
Click here for access to the 42 page Loan Originator Compensation Guide
Read the content of IMMAAG's email by clicking here.
The July 22, 2011 Request for Comments is available here.
The 38 pages containing the comments from the six (6) organizations that responded is available here.
Please feel free to email your comments about the proposal to firstname.lastname@example.org. Even if IMMAAG's request is not successful getting the SRR to re-open the comment period, we will share what we receive from you.
August 18, 2011 - Bureau takes industry feedback on the RESPA/TILA forms development project. For a summary of the 50 minute conference call and industry feedback about the forms project, just click here.
August 1, 2011 - IMMAAG comments on the Interagency Credit Risk Retention and Qualified Residential Mortgage exemption rule. Read IMMAAG's comments here.
July 21, 2011 - IMMAAG submits comment on Board's Ability to Repay Rule - IMMAAG joined 366 other commenters in offering its thoughts about the Board's proposed rule to implement the Dodd-Frank Act's Ability to Repay provisions. The public comment period ends July 22, 2011. A copy of its comments is available here.
July 13, 2011 - IMMAAG posts its summary of the Mortgage Originator Hearing before the House Financial Services Subcommittee on Housing, Insurance and Community Opportunity for regsitered users and subscribers. To access the summary click here. You must log in to access the summary. If you are not registered you can do so (Free and quick) after your click for access.
July 13, 2011 - Republican Gary Miller (CA-42) drops H.R. 2509 to modify loan originator compensation to allow borrower paid compensation to originators employed by brokers and to allow originators to redcue borrower costs when appropriate. Read the one page bill by clicking here.
July 11, 2011 - IMMAAG provides comments to the House Subcommittee on Housing, Insurance and Community Opportunity regarding the July 13, 2011 hearing on the impact of origination changes on homeowners and business. Read the coments by clicking here.
July 6, 2011 - California Republican Congressman Gary Miller offer legislation to merge and revamp Fannie Mae and Freddie Mac. A copy of the bill, H.R. 2413, is available here.
June 29, 2011 - HUD Issues Final Rule on SAFE Act compliance - After more than 15 months since closing the comment period on the proposed rule and only three weeks before its authority transfers to the CFPB, HUD issued a 151 page final rule regarding compliance with the SAFE Act. IMMAAG will provide its review of the rule within the next two weeks. The rule is effective 60 days after publishing in the Federal Register, which the announcement says will be tomorrow (June 30, 2011).
A copy of the announcement is available by clicking here
The full text of the "pre-Register" final rule is available here.
June 24, 2011 - IMMAAG asks Bureau's Dr. Warren to withdraw FRB's MLO Compensation Rule as an early priority in July 2011. Read the request here.
Compensation Misconception Position Statement - click here
April 29, 2011 Letter to Chairman Bernanke - click here
Attachment to Chariman Bernanke letter - click here
Working draft of support letter to Dr. Warren - click here
June 7, 2011 - Agencies extend Credit Risk Retention Comment Period to August 1, 2011 - read the announcement here
May 24, 2011 - Dr. Warren and others testify to the House subcommittee on oversight of the CFPB. IMMAAG is providing a link to the one hour ten minute video and to the written testimony. It is worth some of your time. A subscriber summary will be sent and posted over the weekend (May 28 -29th).
> Video of the testimony available by clicking here.
> Testimony of Dr. Elizabeth Warren - click here
> Opposing testimony - Todd Zywicki and David Evans
> Supportive testimony - Adam Levitin and Andrew Pincus
May 18, 2011 - The Bureau of Consumer Financial Protection (CFPB) invites industry representatives, including IMMAAG to review its first generation of "straw-man" forms which will be tested to cobine and replace the existing GFE and TIL disclosures. Click here to go to the Bureau's new "Know Before You Owe Website", check out the forms, comment and influence an outcome!
May 11, 2011 - Fed's publish Ability to Repay rule in Federal Register - Today the FRB's Ability to Repay proposed rule was officially published in the Federal Register at 76 FR 27390. The 117 page document requests comments no later than 7/22/11 and acknoweldges that the rule will ultimately be finalized by the Bureau. The full text is available here. The IMMAAG Subscriber Table of Contents for the Federal Register version of the rule is NOW (5/12) posted. Subscribers click here to access this tool.
May 6, 2011 - IMMAAG provides subscribers with Ability to Repay Rule Summary, Table of Contents, and an Excerpt of the 80+ specific comments requested by the Board. A word document highlighted version including highlighting the requested comments is available for all visitors by clicking here.
Board's 4/19/11 press release - Ability to Repay Proposed rule here, Check out the 3 page FRB highlight of the rule - here. The full 474 pages are available here.
April 29, 2011 - IMMAAG asks Chairman Bernanke to review misinformation, conduct and internal review and to respond. In a two page letter and a 13 page attachment, IMMAAG provided examples of misinformation used by the Board to justify the originator compensation rule. Click here for the details.
April 26, 2011 - Want to join the action - just send an email to email@example.com and type "Dodd-Frank Materials" in the subject. We will respond with a package you can share with your Congressional member to ask him or her to support an amendment to the prohibitions section of the Dodd-Frank Act. If we do not get this part of the Act amended, the new Bureau will have little choice with respect to the new rule it inherits from the Board in July.
Wonder of Wonders - March 24th Barney Frank asked Chairman Bernanke to revise the borrower paid rule to allow broker companies to pay their employees. He also asked for a change allowing minor adjustments at closing for errors, etc. - read the text of the letter here.
April 5, 2011 - Bad News for Consumers! FRB Rule Goes Live - Read the Appeal Court's one page denial of the motion for a stay - here
4/5/11 - Plaintiffs (NAIHP/NAMB) reply brief - available here
4/4/11 - Feds File Appeal Court Reply Brief - text available here.
Links to attachments supporting user Dodd-Frank Act Amendment Call to Action:
Draft Letter to Your Representative - Not on the House Financial Services Committee (HFSC)
Draft Letter to Your Representative - a member of the HFSC
Draft Letter to Your Senator - Not on Senate Banking Committee
Draft Letter to Your Senator - a member of the Senate Banking Committee
Draft Amendment Language including your talking points
Compensation Position Statement to inlcude as an attachment
NO APRIL FOOL'S DAY JOKE - Circuit court stays the comp rule. Pleadings due by Tuesday, 4/5/11. Read The Stay Here.
March 30, 2011 Judge Beryl Howell, U.S. District Court denies injunction - read the astonishing, myopic 46 page ruling here. NAIHP and NAMB will file appeals 3/31/11.
March 29, 2011 - Agencies jointly publish proposed Risk Retention rule with 174 numbered requests for comment. Comments are due by June 10th 2011. Qualified Mortgage discussions begin on page 63. Access the proposed rule here.
FRB March 17th Webinar Audio with slides available by clicking here.
FRB's March 18, 2011 response to NAIHP & NAMB Lawsuits - no surprises - click here for full text
Click here to access the 106 page NAIHP vs. FRB Lawsuit (Patience please it is slow downloading because of its size.)
Click here to access the 16 page NAMB vs. FRB Lawsuit
Click here to listen to Bill Kidwell's 55 minute interview with NAIHP's Marc Savitt discussing the basis for NAIHP's planned lawsuit to delay the 4/1/11 implementation of the FRB Comp Rule - then join the effort with your refundable support!
Subscribers Only - read IMMAAG's editorial remarks and Mr. Geithner's 3/1/11 full testimony to the House Financial Services Committe regarding Housing Finance Reform - click here.
Register users - click here to read the unedited, full test of Mr. Geithner's testimony.
FHA Announces Premium Increases effective 4/18/11. Click here for the press release and click here for the mortgagee letter.
3/1/11 Chairman Bernanke provides Semi Annual Report to the Senate Banking Commitee - read the copy here.
February 10, 2011 - Copy of House Financial Services Committee (HFSC) Oversight Plan - available here. List of HFSC Members - click here
FEB 1, 2011 - SBA OFFICE OF ADVOCACY ASKS BOARD TO IMPROVE GUIDE AND DELAY RULE COPY OF LETTER HERE
January 28, 2011 - Copy of IMMAAG Letter to FRB - Compliance Guide Issses - click here
Copy of Letter Supporting IMMAAG's 1/28/11 request for rule delay - click here
Read the FULL TEXT of the January 26th FRB MLO COMPENSATION RULE
COMPLIANCE GUIDE BY CLICKING HERE
January 24, 2011 - IMMAAG requests FRB to withdraw or delay compensation rule - Read the letter here.
Your "Call to Action" Support Copy
NMLS&R Call Report Detail Information Available Here.
Summaries of the NAIHP and NAMB lawsuits provided by Jonathan Foxx, our friend at Lenders Compliance Group are available by sending an email to firstname.lastname@example.org. Just inlcude "Lawsuit Summary" in the subject line.
March 11, 2011 - Senators David Vitter and Jon Tester sent a jointly signed letter to Mr. Bernanke on March 11, 2011 asking for a delay of the compensation rule as well. A copy of the letter is available by clicking here. It sites many of the issues that have already been raised including the lack of clarity and the harm to small business as considerations for the delay.