Strict Standards: Declaration of JCacheControllerView::get() should be compatible with JCacheController::get($id, $group = NULL) in /home/oamp/public_html/libraries/joomla/cache/controller/view.php on line 137
The timeframe for delivering the Notice of Escrow of Taxes and Regular Monthly Payment Disclosure Form (“Form”) will change beginning on September 15, 2014 for transactions made under the OMBA.
Under the OMBA, the Form will need to be delivered no later than three (3) business days before a loan is closed. Failure to provide the Form at least three (3) business days before a loan is closed could delay the loan’s closing.
Under the OMLA, the timeframe for delivering the Form remains the same: not earlier than three (3) business days nor later than 24 hours before the loan is closed. See timeline below.
The Ohio Division of Financial Institutions (“Division”) has combined the separate OMBA and OMLA Notice of Escrow of Taxes and Regular Monthly Payment Disclosure forms into one Form for ease of use. The Form is required under the OMBA per Ohio Revised Code (R.C.) 1322.063 and under the OMLA per R.C. 1321.592. The attached Form can be used immediately, but must be used no later than September 15, 2014. This Form is also posted on the Division’s website at:
Note: The initial Good Faith Estimate and Truth In Lending Act disclosures do not fulfill the requirements of R.C. 1322.063 and 1321.592. The Division requires the use of the attached Form until the new Federal Closing Disclosure Forms come into use, scheduled for August 2015. The Division will notify you when the attached Form is no longer mandatory.
The rules revision process for the Ohio Mortgage Broker Act is moving forward, but our work is not yet complete.
Since early last fall we have attempted to engage the local, state and national associations in our process of updating and evolving the Ohio mortgage rules. We have also reached out to community groups, compliance firms and our registrants to gain their viewpoints and concerns about our mortgage rules. Many of you have been an integral part of this process, and helped define the rules as they have evolved through the months of work. We have clarified them, used a ‘word diet’ on them, and wherever possible chose to use plain language more suited for our industry. But we are not yet done.
We will soon file the draft rules and formally start the countdown ticking. We will then hold both a public hearing here at the Division and a public hearing with the Joint Committee on Agency Rule Review. You are invited to attend and share any thoughts on the rules – whether in support or in opposition to the Division’s proposed rules. Only then can the rules become final. We will share the dates for those opportunities when they are known so that anyone interested can attend either or both hearings.
But even after all of this work and hearings, the work it is still not complete. I am asking for the opportunity to come to you and share more detail about the changes that have been made as well as how the Division will be enforcing these new rules. Please let me know what opportunities exist to come to your meetings this fall or next spring and answer the questions from your members.
Our process has encouraged participation and allowed for transparency in how the rules were developed from both state and federal law. It is our sincere hope that by sharing more detail with your members that we can provide predictability for mortgage compliance in Ohio. Yes, we would choose for your compliance over a necessary act of punishment. I personally thank everyone who has taken part in this process. I also look to an opportunity to share more about protecting consumers while allowing mortgage companies to grow here in Ohio.
Please feel free to call or email me directly,