The MBA continues to gather information, and came out with its latest compensation benchmarking study. "MBA's benchmarking studies offer mortgage companies better business intelligence when making important personnel and operational changes to adapt to this regulatory climate. For ten years, MBA has recommended the annual Residential Mortgage Banking Compensation Survey Program to its members (and every lender) as they develop and implement their individual compensation strategies. This year's program includes the 2014 Residential Compensation Survey that profiles more than two hundred positions across all mortgage-related lines of business and functional areas. Among the elements covered: base salary, cash bonus, total cash, commissions, overtime, total compensation and long-term/deferred awards. Reports include scoping factors such as geographic region, number of employees, revenue size and total loan volume. In addition, productivity data is collected and included in the report at the individual level (i.e. loan officer loan production); three specialized compensation benchmark products that are focused on production, servicing and corporate/executive functions; a 1½ day MBA Human Resources Roundtable in September. Open to participants in the survey, this interactive workshop offers a unique opportunity for attendees to network with peers, while analyzing the latest in compensation benchmarking data and human resource trends. Results from the 2014 Residential Compensation Survey will be presented. Registration and participation in the program is required in order to receive the results and MBA members receive a significant discount off the regular survey pricing. The survey questionnaires will be sent in March. Publication of the survey is anticipated for August 2014. Please complete the registration form today to secure your firm's participation in this program, or if you have general questions, please contact Marina Walsh, MBA Research, at MWalsh@mba.org.
The
MBA is definitely following the HMDA developments. But what do credit unions think of the
CFPB's quest for more HMDA information?
The
MBA sent out an update saying, "The CFPB began the process of revising the
Home Mortgage Disclosure Act (HMDA) rules to require lenders to collect and
report several new data elements. Some of these new data elements are
specifically required under Dodd-Frank. However, the Bureau is also
considering requiring some additional data elements. The CFPB is also
considering changes to the collection rules to streamline reporting and improve
data entry. Finally, it is also considering revising the reporting thresholds
so all banks and non-banks report if they make 25 or more mortgage loans in a
year. A summary of the data elements sought by the CFPB is here. Notably, Dodd-Frank
adds the following HMDA data elements (unless the CFPB decides otherwise):
total points and fees, and rate spreads for all loans (not just HPMLs); risky
loan features including teaser rates, prepayment penalties, and non-amortizing
features; the length of the loan; expanded lender information, including a
unique identifier for the loan officer and the loan; property value and
improved property location information; borrower age and credit score.
The
CFPB is also considering requiring: mandatory reporting of reasons for denial;
debt-to-income (DTI) ratio; Qualified Mortgage status of loan; combined
loan-to-value (CLTV) ratio; automatic underwriting systems results; additional
points and fees information (including interest rate - HMDA requires APR
currently, total origination charges, Bona Fide and Total discount points,
risk-adjusted, pre-discounted interest rate); whether loan has affordable
housing deed restrictions; and manufactured housing data.
As
a first step in revising the rules, the CFPB has convened a small business
review panel required under the Small Business Regulatory Enforcement
Fairness Act (SBREFA) to provide
input on the changes under consideration, focusing particularly on the burden
these requirements would create. Over the next few weeks, the CFPB will conduct
several conference calls with the SBREFA panel and an in-person meeting in
Washington DC in early to mid-March. Following the conclusion of the panel's
work, the CFPB is expected to issue a proposed rule. At least four members of
the panel are employees of MBA member companies and MBA is acting as a resource
to industry panelists. MBA believes that the new data collection requirements
present several important concerns that must be resolved to avoid undue
operational burdens and litigation risks-especially in light of HUD's recent
disparate impact rule. MBA also wants to ensure that consumer privacy is not
compromised under any new HMDA regime. MBA will raise these and other issues in
the rulemaking process. We are at the beginning of what should be a lengthy
process. Any new HMDA rules are unlikely to require new data until 2016 at
the earliest. We will provide updates as this important process moves forward."
Has
anyone head about the government expanding HARP? If they do, will we
see another refi boom?" I hate to be the bearer of bad news, but a story
in Bloomberg last week filled us in. "HUD's Donovan Confirms HARP Won't Be
Expanded, FBR Says." "Now HUD has joined the Treasury on doing nothing
with regard to HARP, which makes it a bit more difficult for Watt to garner
support for material changes." "HUD Secretary Shaun Donovan made
it clear yesterday at a Politico event that his department. Will not push for
HARP expansion, confirms that no broadening of program should be expected, FBR
analyst Ed Mills writes in a research note. Donovan believes improving access
to credit for mortgage borrowers remains HUD's most important policy challenge.
Sees Wells Fargo's pursuit of 600-640 FICO FHA borrowers as positive sign for
credit availability. Donovan is cautiously optimistic about FHA's finances;
following last year's infusion of taxpayer money into FHA, many in Washington
concerned about its balance sheet."
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