It is out! Federal agencies jointly released a highly anticipated proposed rule that, when finalized, will implement the creditor risk retention requirements (Section 941) of the Dodd-Frank Wall Street Reform and Consumer Protection Act and related provisions on qualified residential mortgages (QRM). There is grave concern about what the federal regulators have brewed in Washington, as this proposed rule will severely constrain the availability of reasonably priced mortgage financing and its impact is expected to trickle down to settlement services businesses, consumers and everyone a mortgage loan touches.
Our speakers are analyzing this highly impactful rule and will bring you complete instruction in this 90-minute Webinar. Our legal and compliance experts will provide you with full instruction on what the regulators are proposing so you will have the knowledge and insight to comment on the rule, as well as insight into the statutory framework of the related Dodd-Frank provisions.
This Webinar will:
- Explain the general risk retention requirement and narrow QRM exception to the requirement;
- Explore the major components of the QRM exception, including the 20 percent down payment requirement, underwriting requirements, prohibited loan features and servicing requirements related to loss mitigation;
- Address how the QRM exception may effectively define what loans are originated;
- Explain a reduced risk retention requirement provided for in Dodd-Frank that is not addressed in the proposal; and
- Address actions that industry members may want to take to address the proposal.
The risk retention/QRM proposal likely will have a dramatic affect on the residential housing and settlement services industries. The proposal reflects the intent of regulators to implement strict standards that will substantially limit the types of mortgage loans that are available and the persons who qualify for mortgage loans, and to also impose certain nationwide servicing standards for mortgage loans.
Legal authorities are strongly encouraging mortgage lenders, brokers and servicers, title companies, real estate brokers and agents, and other settlement services providers focus on the risk retention/QRM rules. These rules literally may threaten your business by substantially reducing the number of real estate sales and refinancing transactions, and imposing significant loss mitigation requirements for the servicing of loans.
Partner, Patton Boggs LLP
Rich Andreano is a partner in the Washington, D.C. office of Patton Boggs LLP. His practice focuses on federal and state mortgage lending and consumer credit compliance issues, including matters involving the Real Estate Settlement Procedures Act, Truth in Lending Act, Equal Credit Opportunity Act, Fair Credit Reporting Act, Home Mortgage Disclosure Act and Gramm Leach Bliley Act.
His practice includes advising clients regarding regulatory compliance matters; assisting clients in establishing mortgage lending and brokering programs, affiliated business arrangements, service arrangements and marketing and promotional programs; assisting clients with transactional matters and representing clients in connection with RESPA, fair housing, and other administrative enforcement actions.
Andreano is a frequent speaker on matters of interest to the mortgage lending industry, including presentations at conferences sponsored by the Mortgage Bankers Association and the Real Estate Services Providers Council. He presents the RESPA section of the annual Regulatory Compliance School sponsored by the National Association of Federal Credit Unions. He is the editor of RESPA/Escrow Issues.
Andreano received a Bachelor of Arts degree, with high honors, from the State University of New York at Oneonta, and a J.D. degree, with honors, from George Washington University. He is a member of the District of Columbia Bar, Virginia State Bar and American Bar Association.
Contact: [email protected]
Chief Legal & Compliance Officer, Mortgage Cadence
John Levonick is the chief legal and compliance officer at Mortgage Cadence. He is responsible for working closely with Mortgage Cadence clients on identifying and managing compliance risk. In drawing from his advisory experience, John assists clients in interpreting compliance requirements, developing risk mitigation strategies and implementing the requisite controls within the Mortgage Cadence platform(s) to best protect the individual client.
Prior to joining the Mortgage Cadence compliance team, John worked with creditors, servicers, secondary market participants and technology vendors in providing guidance on mortgage lending laws such as TILA, RESPA, FDCPA, FCRA/FACTA, ECOA, HMDA and GLBA (including fair lending, state anti-predatory and consumer credit). He was also responsible for overseeing the compliance content of vendor technology platforms, including policy tracking, interpretation and rule implementation.
His experience as chief compliance officer, regulatory counsel and associate general counsel in the mortgage lending industry has given him the skills to provide the guidance and direction required to navigate the challenges of a constantly changing regulatory environment. John earned his Bachelor of Arts from Eastern Connecticut State University and his J.D. from the University of Miami, School of Law.
Contact: [email protected]