May 18, 2022
While we have been hesitant to discuss the new qualified mortgage rule in the CBC, as we thought it might change, the CFPB has recently issued new information regarding qualified mortgages and ARM loans, which leads us to believe that the qualified mortgage rule will change on October 1, 2022, as scheduled. The APR impacts qualified mortgages directly, and also impacts the other topics in the presentation.
Qualified Mortgages: The first subject will be the new qualified mortgage rule, which is fairly simple, but does have some issues that we will need to address for certain loan types. As with all the other topics in the presentation, the APR is the factor that will determine whether you have a qualified mortgage.
Higher Priced Mortgage Loans (HPML): The second subject will be HPMLs. This portion of the regulation contains a very similar calculation that will be used for qualified mortgages beginning October 1, 2022. HPMLs represent approximately 10% of the loans that are made across the country, based on HMDA data, and many of the HPML loans are adjustable-rate mortgages – but not all of them. As pricing becomes more critical based on our current economic situation, HPMLs may become more prevalent. We will review both the calculation and the impacts that HPML loans will have on the bank and the customer – including escrow and appraisals.
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8:30 a.m. Registration & Continental Breakfast
9:00 a.m. Program Begins
12:00 p.m. Lunch (included)
1:00 p.m. Program Resumes
4:00 p.m. Program Adjourns
Subjects for future seminars will be shaped by regulatory events as they unfold. The CBC quarterly compliance program remains committed to providing as much up-to-the- minute information as possible. The program will closely monitor releases from the CFPB and other agencies to assure that you have the most up-to-date and accurate information possible.
The subject matter for this presentation was determined from requests received from CBC members regarding subjects that they wanted addressed in 2022. Additional suggestions are always welcome, and can be sent to Bill Elliott (bille@younginc.com) at any time.
Bill Elliott, CRCM, Sr. Consultant, Director of Compliance.
Bill Elliott has over 40 years of banking experience. At Young & Associates, he leads compliance seminars, conducts compliance reviews for all areas of compliance, conducts in-house training, and writes compliance articles and training materials. During his career, Bill spent 15 years as a compliance officer and CRA officer in a large community bank and worked for a large regional bank. He has been a lender for consumer, commercial, and mortgage loans, and has managed a variety of bank departments, including loan review, consumer/commercial loan processing, mortgage loan processing, loan administration, credit administration, collections, and commercial loan workout. He holds the designation of Certified Regulatory Compliance Manager (CRCM).
High-Cost Loans (HOEPA): The acronym HOEPA is for the Home Owner Equity Protection Act. Once again, a calculation similar to the qualified mortgage calculation is used to determine whether you have an HOEPA loan. While there are very few loans that meets the HOEPA standard, a HOEPA loan causes significant difficulties for your institution - once again including escrow, appraisals, as well as other issues such as mandatory home ownership counseling.
Military Lending Act (MLA): The last subject of the day will be the Military Lending Act. Like the other three topics, the APR - and most especially the Military APR - determines whether you have an issue under the MLA. We will discuss the implications of exceeding the Military APR on an MLA related loan. We should note that some MLA related loans are not mortgages.
WHO SHOULD ATTEND
Compliance officers, lending management, lenders and processors, and any others with responsibilities for lending should attend. Additionally, audit personnel will find this session useful.
PANDEMIC RELATED NOTICE:
In an effort to maintain the safest environment for your educational session, the IBA monitors the status of COVID-related cases in Marion County and the state of Indiana, on a daily basis. If the Weekly 2-Metric Score for Marion County is Orange (2) or above, two weeks prior to your session, the IBA reserves the right to transition this event to a virtual format. You will be notified of any changes to this event, two weeks prior to its scheduled date.
$350 IBA Member
$180 Each Additional IBA Member
100% Surcharge is applied for Non-Members.
This seminar will also be offered on Wednesday, May 18, 2022 at Indiana Wesleyan University Fort Wayne Education and Conference Center located at 8211 W Jefferson Blvd, Fort Wayne, IN 46804.
This seminar will be also be held as a hybrid event Tuesday, May 17, 2022 at the IBA Center for Professional Development, 8425 Woodfield Crossing Blvd. Suite 155E, Indianapolis, IN 46240. Attendees can choose to attend live or virtually. Please see the registration page on May 17th to enroll for this session.
If choosing to take this course online, we still look forward to “seeing” you! You will receive your manual 2-3 days in advance should you want to print this to have during training. At this time, you will also receive log in instructions. This is a completely LIVE virtual training where you will be able to ask questions directly to the speaker.
Elizabeth DeHaven, Education Manager
EDeHaven@indiana.bank
317-333-7169
You will receive an e-mail confirmation at
Within three or more business days prior to the day of an educational program, no cancellation charge will be assessed. Within two days prior, 50% of the fee is assessed. Refunds are not provided for cancellations the day before or absences on the day of the program. Substitutions are welcome at