With all of the new and changing compliance rules coming at us hard and fast, you may have discovered that there are some differences in forms you may not have thought were changing on you…but did!
So with help from our in-house compliance expert, I’m going to tell you about three of the more unexpected and question-prompting compliance changes.
TIL: Concern over the content of the ‘MAXIMUM during FIRST FIVE YEARS’ column in the TIL disclosure for 5/1 ARMs. Specifically, the heading for the column doesn’t match what is shown in the column.
In the Truth-In-Lending interim rule, published in December 2010, the FED states that for the Maximum interest rate during first five years, “the Board intended that creditors disclose the first rate adjustment for a “5/1 ARM.” Therefore, although the new interest rate and new payment do not take effect for the borrower until month 61, the FED required the TIL disclosure show the first rate adjustment in the MAXIMUM during FIRST FIVE YEARS’ column.
Statement of Credit Denial form: The old form pre-filled all 3 credit agencies and the credit scores.
The Dodd-Frank Act amended requirements in the Equal Credit Opportunity Act (ECOA) and the Fair Credit Reporting Act (FCRA) related to adverse actions. Recently the FED released a final rule that updated the model notices in Reg B to reflect the new content requirements defined in the Dodd-Frank Act. The new model form only requires you to enter one agency and score.
For step by step instructions on printing the credit bureau address on the form, visit our Knowledge Base #0273.
VA Certificate of Eligibility: There has been concern that this form is pre-populating fields in the print form.
The form (like most in Point) is designed to be populated through the Point screen. So what users are seeing is that the default behavior for some of the check boxes (make the ‘No’) in the form. This is not uncommon behavior in other forms in Point. If you look at the form in Print preview, you will see the default checks. This is the only ‘pre-filling’ in this form.
If you have additional questions about these or other compliance concerns, please call our helpful support group at 800-342-2599.