The new forms are not going into effect until Aug. 1, 2015, a gap which Don Frommeyer sounds slightly incredulous about. The real question is if CFPB will continue to modify the proposed forms in anyway or will the industry have two years to prepare to implement them.
The new forms do not define if lender-paid compensation is considered to be an origination fee, Frommeyer says.
Therefore what is on CFPBs website seems to be a bank disclosure but not one which is usable for brokered loans, he says.
Lender-paid compensation is not a loan origination fee, it is not an application fee and it is not really points, all of which have their own boxes on the new forms.
Under the qualified mortgage rule, fees are capped at 3% to meet the test. That area is still a concern for his membership. An internal survey found 60% are at least considering becoming a mini-correspondent. Everybody is still waiting to see if the CFPB will make changes to QM, and they are looking forward to what the agency might say in Boston today, he says.
The August 2015 implementation date is being praised by the Mortgage Bankers Association, which adds it is a sign CFPB recognizes the enormity of the change and the time needed to implement it.
The group will comment later on the specifics of the proposal, it says in a statement.