Which New Requirements Apply to HELOCs?

Which New Requirements Apply to HELOCs?

April 10, 2013 2:00 p.m. ? 3:30 p.m. EST

Presented by:

Steve Van Beek, Esq., NCCO Director of Regulatory Compliance National Association of Federal Credit Unions

National Association of Federal Credit Unions l

Webcast Goals

? Which DON'T APPLY to HELOCs? ? Which Requirements Apply to HELOCs? ? What Action Steps Do You Need to Take?

? Where to Find New Requirements ? Details of New Requirements ? Is your HELOC covered?

? Effective Dates of New Requirements ? Which Requirements Will Take the Most

Resources? Headache Areas?

National Association of Federal Credit Unions l

7 New Regulations

1. Escrow Requirements for HPMLs 2. Loan Originator Compensation & More 3. Mortgage Servicing (Reg Z & Reg X) 4. Qualified Mortgage/Ability-to-Repay 5. Requirements for High-Cost Mortgages 6. Appraisal Requirements for HPMLs 7. Appraisal Disclosure & Delivery

National Association of Federal Credit Unions l

HELOCs EXCLUDED

1. Escrow Requirements for HPMLs 2. Appraisal Requirements for HPMLs 3. New Ability-to-Repay Requirements*

and Qualified Mortgage Standards 4. 8 of 9 New Mortgage Servicing

Requirements 5. MLO Compensation, Qualifications,

Training & Disclosure Requirements

National Association of Federal Credit Unions l

HELOCs COVERED

1. Prompt Payment Crediting 2. Payoff Statements 3. Prohibition on Mandatory Arbitration 4. Prohibition on Financing Single-Premium

Credit Insurance 5. IF FIRST LIEN ? Reg B Appraisal (and Written

Valuation) Disclosure & Delivery 6. Homeownership Counseling Disclosure

Requirement

National Association of Federal Credit Unions l

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