2017 Talking Points
- Correction to the 3% Qualified Mortgage Rule
mortgage broker business model has a disadvantage due to the
calculation of the 3% borrower closing costs rule. The Qualified
Mortgage rule was not intending to cap the fees paid to the originator
by the lender, only by the borrower. CFPB has
even written about this problem, saying that they have done what they
can with regulations, this requires a statutory fix.
- Transitional License
year we opposed the Transitional License as it allowed people that had
not passed the Federal Exam or the FBI Background check, to get a
Transitional License for 120 days. Only about 50% of people pass the
exam the first time, meaning that nearly half the people getting the
Transitional License would fail to successfully transition to full
license without a gap. We believe that is misleading to the
people trying to transition to licensing and unwise to subject the
public to people that are not prepared. The proposal has been
modified and now requires the person transitioning to pass the Federal
Exam and the FBI Background check before he/she can be issued a
Transitional License. We support the new proposal.
- CFPB needs to give written guidance
if you have a question about how a law or regulation applies to your
specific circumstances, you can ask the Federal agency that regulates
that issue to answer questions about how to handle your circumstances.
That agency must live by their answers. The CFPB is not
required to provide answers and in fact, when they speak at a public
event they precede their remarks with a disclaimer that disclaims
everything but their presence. This proposal would require CFPB
to anwser questions in writing and to live by their answers. We
support this proposal.
- Flood Insurance Reauthorization
National Flood Insurance Program (NFIP) is subsidized by the Federal
Government and if its funding stops, other Federal laws prohibit
lenders from financing properties that are located in certain
designated flood zones without flood insurance. If the financing
is halted, sales in coastal communities will halt and property values
will plummet until cash buyers come into the market. Millions of
people would lose most of their wealth if this happens. The National Flood Insurance Program needs to be re-authorized by September 30th, 2017.