While watching for changes in our turbulent industry to stay on top of what we need to know for training and NMLS compliance you see things. Sometimes things you wish you didn’t
The Federal Reserve’s draft of the newly proposed Truth in Lending Act places limits on the Yield Spread Premium that can be charged by Brokers/Loan Originators.
Many consider this a disaster that will serve to be a burden to small business and end competition.
This is about your future if you are a Loan Originator Or a Broker, SPEAK OUT NOW AND LOUDLY.
The draft is in it review and comment period so go to the link below and let them know how you feel! It is your future.
http://www.federalreserve.gov/generalinfo/foia/proposedregs.cfm
Lloyd Ball
Lloyd, your right, keeping up with changes in training and the NMLS are enough, but it is what it is.
I lifted this from the FED Press Release. It looks to me like YSP would be prohibited entirely.
In developing the proposed amendments, the Board recognized that disclosures alone may not always be sufficient to protect consumers from unfair practices. To prevent mortgage loan originators from “steering” consumers to more expensive loans, the Board’s proposal would:
• Prohibit payments to a mortgage broker or a loan officer that are based on the loan’s interest rate or other terms; and
• Prohibit a mortgage broker or loan officer from “steering” consumers to transactions that are not in their interest in order to increase the mortgage broker’s or loan officer’s compensation. Full Press Release: http://www.federalreserve.gov/newsevents/press/bcreg/20090723a.htm
Note the title Loan Officer – doesn’t that make this apply to BANKS TOO! If it does and banks have to disclose at the same level we do, I can live w/o YSP Chris G