Newsletter - Important Compliance Information

June 23, 2009
Vermont Mortgage Bankers Association
 Newsletter - Special Compliance Edition
In This Issue
VT SAFE Act Requirements
Continuing Education Requirements
VMBA Seeks Status as NMLS Approved Provider
HMDA Changes Effective 7/30
HVCC Concerns - Speak up!
Great Day for Golf
MBA Letter to Members on Obama Regulatory Reform Proposal

June 17, 2009

"...The proposal is wide-ranging and will have significant impact on the mortgage industry....

Link to:
MBA Reaction to Proposal

Summary of Proposal

Proposal
Text-85 pgs



1st Quarter MBA National Delinquency Survey

MBA NDS

 
Platinum Sponsors

Strategic Information Resources
Maureen Devine

Vermont Housing Finance Agency
Erin Perrin


Diamond Sponsors

Chittenden Bank


Law Offices of Fred V. Peet


Vermont Attorneys Title Corporation



Save the Date

VMBA Summer Gala at the Burlington Boathouse

Wednesday,
August 5th
5:00 - 7:30


Two Winners of Three Red Sox Tickets each will be drawn at the Gala.  Purchase Raffle Tickets Online Now



Showcasing our Legal Community
Members

 
Coombs, Davis & Hill

Law Office of Fred V. Peet

Ward & Babb

Wick & Maddocks Law Offices

Wiener & Gale

Vermont Attorney's Title Corporation


Title Insurance Group of Chicago,  Lawyers and  Commonwealth

Thanks to our

Attorney and Title
Insurance

Affiliate Members for your support.


Please Support those who Support us!



 All Member Employees are Welcome!
Please be sure all who would benefit from our news receive this newsletter.
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Are you Ready?
It's Time to Prepare, Plan, and Stay Informed.
Significant changes affecting the mortgage lending industry will soon be effective both on the State and Federal level.

On May 21, Governor Douglas signed into law critical legislation, H-171.  These new requirements will drive much of the VMBA educational program content going forward. 

VMBA will work to bring the information you need to understand and comply with these new rules. 

Diane Smith
Executive Director
Vermont Mortgage Bankers Association
Key Points of H-171 (SAFE Act):
  • All Vermont State Licensed Lenders and Brokers must complete 20 hours of NMLS Approved Pre-licensure Education and Tests by July 1, 2010
  • Pre-Licensing requires 20 hours education including:
    • 3 hrs Federal Law & Regulation
    • 3 hrs Ethics, including fraud, consumer protection, and fair lending
    • 2 hrs Lending standards for nontraditional mortgage products
    • 12 hours Other Approved NMLS courses
Note - VT specific education is not required - however, a VT Test is required for all VT Licensed Lenders and Brokers. You must know VT Lending Law in order to pass! Appropriate VT Lending Law classes will be offered.

Individual Test fees: $92 National component + $69 VT = $161

Initial Lending Licenses must be obtained by July 1, 2010.  All applicants must pass the Federal and Vermont tests, and successfully complete the PE education.

Current Licensed Lenders and Brokers - you have until December 1, 2009 to meet the Bond and liquid asset requirements of the new revisions to 8 VSA 2203.


What's Next?
After you have met the requirements of the initial VT Lending License, the following is required annually, prior to December 1, when a renewal of the VT Lending License is due.

Annually Licensed Lenders must successfully complete:
  • 8 Hours Continuing Education Annually:
  • 3 hrs Federal Law & Regulation
  • 2 hrs Ethics, including fraud, consumer protection, and fair lending
  • 2 hrs Lending standards for nontraditional mortgage products
  • 1 hour Other Approved NMLS courses
Beginning in 2011, VT License renewal required on or before December 1 annually requires the above CE.
 
Annual Continuing Education classes will count only in the calendar year in which they are taken.
The same CE class may not be taken two years in a row.
 
Burlington BoatHouse

These changes affect VMBA as well, and we also are preparing for our future.  Our primary mission is to provide quality education to our members close to home, and we expect to be ready to continue to do this for you.  Essentially VMBA is:
  • Preparing to apply for approval by NMLS as an Approved Provider of Educational classes
  • Preparing a series of classes to submit to NMLS for Approval as Pre-Licensure Educational credits (PE credits)
Our anticipated schedule of  NMLS Approved Pre-Licensure Education is:
  • September - 4 hours Federal Law
  • October - 6 hour program (two sessions)  4 hours State Law - VT Test Preparation (Elective credit), 2 Hours  Reverse Mortgage (Nontraditional credit),
  • November  - 3 hours Ethics credit - Credit Bureau and FHA Fraud Prevention
Total Credits expected to be offered by VMBA in VT before December is 13.  If approved as outlined, these classes will satisfy the required classes for Pre-Licensure.  Twenty credits are required by July 1, 2010.  We anticipate the remaining 7 hours (Elective Credits) will be offered by VMBA through the winter.
 
In addition to making plans for VMBA to offer the initial licensing classes and the continuing education classes, your Board of Governors is considering a proposal to form a New England regional MBA.  Regardless of the outcome of merger discussions, we anticipate continuing to work with our New England neighbor MBA's to partner with classes as appropriate.
 
At this time, I need to hear from our Members.  The mandatory Education for Licensing changes the dynamics for VMBA, and makes it difficult to plan on attendance.  If a representative from each of our lender members would email an estimate for your company the number would likely register for the above programs. This is not binding - just an estimate.  However with so many of you required to take classes, yet a lot of providers competing to provide the credits, it's hard to know what size facility to reserve.
 
Please know that VMBA will incur significant additional costs in getting our classes approved for Licensing Education. However, we'll work to keep our costs as low as possible.
MBA SUMMARY
HMDA Changes Take Effect July 30

Summary - Federal Reserve Rule Implementing
Mortgage Disclosure Improvement Act of 2008, as amended
74 FR 23289; May 21, 2009

Background - This final rule published by the Board of Governors of the Federal Reserve (Board) on May 19, 2009 amends Regulation Z (Truth in Lending) to implement the Mortgage Disclosure Improvement Act (MDIA), as amended.1
Overview - (1) Extends the requirement for transaction-specific good faith estimate or early TILA disclosures that include, for example, the amount financed and the Annual Percentage Rate (APR), to all dwelling-secured credit transactions except Home Equity Lines of Credit (HELOCs); (2) Establishes waiting periods between the time when disclosures are given to consumers and consummation or closing of the transaction; and (3) Establishes procedures for consumers to waive or shorten such periods based upon a bona fide financial emergency.
Effective Date - Becomes effective on July 30, 2009, two months before the Board's pending regulatory changes to its TILA/Home Ownership and Equity Protection Act (HOEPA) rules which become effective October 1. MDIA also includes provisions requiring additional disclosure language for adjustable loans but these provisions will be implemented later.


CampusMBA & VMBA Co-Sponsor

New TILA Requirements - Live Online Workshop
 1st offering on June 23, 2009 AND "Encore" Mid-July
2:00 p.m. - 3:30 p.m.
Call CampusMBA to Register a site at
1-800-793-6222, select option 3 between 9:00 and 5:00  Monday through Friday.


Save the Date!
Wednesday, Sept 9, 2009

    RESPA Update
                    Ruth Dillingham, First American Title             
Burlington.
                     

Raise your Voice
Our industry is dealing with challenges created by HVCC - the Home Valuation Code of Conduct.

Link here to a Special Announcement from the Mortgage Market Guide, brought to us by one of our lender members. 
For more information and links on the HVCC, go to our Spring Newsletter, posted on our Vermontmba.org website.

VMBA 2009 Golf Open
A great success!

Check out the Photo's posted on our Website!

What a beautiful day we were rewarded with thanks to Rocky Ridge's offer to move the date a week for us. 
Following were the winners this year -
congratulations to you all!


Putting Contest - Kevin Shortell
Closest to the Pin - Tom Connors
Men's Longest Drive - Nick Antell
Women's Longest Drive - Jessie Cook

1st Place Gross Score AND 1st Place Net Score -
Greg Hahr, Paul Hill, Steve Laquerre & Ed Levite

2nd Place Net Score - Dave Adams, Patti Brosseau,
John Hood & Rob Wheeler

3rd Place Net Score - Ande Deforge, JJ Hamilton,
Henry Rackliff & Steven Roberts
Diane Smith
Executive Director
Vermont Mortgage Bankers Association
866-680-8622
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