Last week the CFPB introduced "Rate Checker", a tool on their website that quotes interest rates to borrowers. Not only did the CFPB develop this tool without any industry input, the CFPB violates the very rules that lenders are required to comply with under federal regulations. Rates are quoted without an APR or disclosing closing costs. And why is a government agency quoting interest rates in the first place? The OAMP and the OMBA are very concerned with the scope, methodology and future plans for enhancement of this tool.
It's time for you to get involved.The OAMP and the OMBA asks two things from you:
- Send a message to your Congressman and Senator about this issue. If you are a member of the Mortgage Action Alliance (MAA), you can go to the MBA website http://www.mba.org/ and take action. If you are not a member of the Mortgage Action Alliance, join by clicking here. Once you have joined, you are able to "take action" and send a message to your members of the Legislature. The message is already written for you, and can be sent with just one click. However, the message is editable, if you choose to make changes before sending.
This intrusion into your business is serious. If the CFPB won't voluntarily take down the site, we must depend on Congress to get it done. Your participation in this effort is crucial. To view Rate Checker, click here.
GREAT NEWS!! The Ohio Division of Financial Institutions’ (“Division”) 2014 Annual Report under the Ohio Mortgage Broker Act has been replaced by the NMLS quarterly call reports! Entities under the OMBA are not required to submit a 2014 Ohio Annual Report. All necessary information will be collected from the NMLS MCRs, thereby alleviating the process of reporting Ohio-specific information.
Accordingly, it is imperative that all MCR information is accurate. If this means amending reports from any previous quarter, please do so immediately. The NMLS does not assess a fee for amending previous reports, and all companies are encouraged to ensure previously reported information is current and accurate.
To ensure all companies are submitting true and accurate information on the NMLS MCRs, MCRs will be a point of note during the Division’s examinations. Examiners will be verifying all information submitted to the NMLS for accuracy.
NOTE: If a company registered under the OMBA also held an Ohio Mortgage Loan Act (“OMLA”) certificate of registration and/or Ohio Small Loan Act (“OSLA”) license at any point during 2014, these 2014 Ohio Annual Reports are still required to be submitted. Please watch for postal mail correspondence containing the company’s Username and Password that was sent to the company’s main mailing address on file.
The Division extends its thanks in advance for your cooperation in timely submitting all NMLS MCRs. If there are questions regarding this email, please feel free to respond to this message.
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,