The good new is for those who could not listen or make the call, we did record it. Links are below:
Click Here for Audio
We had hundreds of questions. Jim answered as many as he could. If the subject is still not clear to you–then join the club. Jim’s presentation was “clear as a bell,” only the bell is not so clear. Without written guidance from the Fed, everyone is searching in the dark here somewhat. The Fed did just release a guide for small businesses on this issue, thanks to those who sent the link: http://www.federalreserve.gov/bankinforeg/regzcg.htm
I consolidated as much as I could so I did not overwhelm Jim and he was kind enough to give us some additional written answers that appear in another post. I also answered some individually (simple ones) and some feedback that will cover many others is as follows:
- The Good Faith Estimate has nothing to do with the TIL regulations. The GFE is administered by HUD under RESPA. TIL by the Fed. Of course, you would have thought they would have coordinated, but do not be surprised if they conflict and will have to be reconciled at a future date. The new Bureau is actually supposed to combine the two forms.
- YSP vs SRP. SRP was not addressed by the rules as far as I know. SRP is not an issue for brokers but if a lender now uses that to pay a LO–if it takes a loan “above par” it is in fact part of YSP—and will probably have to be built into rate sheets like any other YSP. That is just conjecture on my part.
Jim has been very kind with his time, and if you are looking for legal advice, please consider Jim Milano at WBSK, phone number 202-628-2000 and email address. firstname.lastname@example.org. I am hoping he will help us deliver one more of these if we get some written guidance from the Fed, but that is not certain.
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