Originator Summit – The Fed, Our Industry, and Your Compensation:
FRB Proposed Changes To Reg Z – What You Need to Know and Do Immediately
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We know the Fed does NOT understand the implications of the proposed changes to Reg Z – and the negative impact it will have on consumers. The harsh reality is… mortgage brokers and loan originators now face an unwarranted and misplaced attack on one of the pillars of their compensation. Worse yet, this proposed rule will actually hurt the very consumers it aims to protect! Many of you heard the shocking and frightening call Mortgage Success Source held with Federal Reserve Attorney Paul Mondor. We must take action now before the rule is finalized. Action Items:* Click on Call to Action links for easy instructions: |
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Purpose for call: This one-hour webinar features mortgage originators and industry experts discussing:
Background: In its August 26, 2009 final proposed rule offering changes to Regulation Z the Federal Reserve Board proposed on page 42379 to include: “36(d) Prohibited Payments to Loan Originators: The Board is proposing to use its authority in HOEPA to prohibit unfair or deceptive acts or practices in mortgage lending to restrict certain practices related to the payment of loan originators.” This section of the proposed rule finally illuminates the Board’s perceived source of a problem created by misconception that has persisted in the mortgage industry for decades. The Board’s proposed rule asserts that certain practices related to the payment of loan originators are unfair or deceptive. (See, Federal Register, Vol 74, No. 164, page 43279, August 26, 2009) In fact, this is the only justification the Board can invoke to support any action to deal with loan originator compensation. Absent creating a nexus between unfair/deceptive, the Board is without legislative authority to suggest such broad powers under TILA. But arguing the Board’s authority is not the purpose of this paper. Earlier in the proposed rule (page 43240) it refers to the offending practice as the payment of “yield spread premiums”. As a primary result of the misunderstanding, these regulations now contain requirements and disclosures that not only do not further the purposes of goals of the RESPA or TILA, but rather cause and perpetuate the use of confusing, obscure and counter productive disclosures. Further, the misconceptions have redirected the national debate away from enabling the accomplishment of the goal expressed by all, i.e. to produce simpler, clearer, more easily understood and usable disclosure to protect consumers to an irrelevant and unproductive debate about how lenders use of their revenue must be controlled. Action Items For Loan Officers – 5 x 5 x 5 Campaign * Click on Call to Action links for easy instructions: To maximize this effort we are asking every Loan Originator to engage in a five-part letter and email campaign. 5 Print and send (or email/fax) the 4 letters to the Fed and HUD. Send 1 copy to admin@IMMAAG.com so we can track the volume. 5 Forward this website and put a personal call to at least 5 other Loan Originators you know, and ask them to do the same. 5 Spend 5 minutes on your social networking and add a link to this site on Facebook, Twitter, Blogs, Media Outlets etc. Let’s get the word out and forward this site to as many people as we can! |
Action Items:* Click on Call to Action links for easy instructions: Supporters:
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