Untangling the Web of Fee Disclosures Webinar

“Oh what a tangled web we weave”… Walter Scott was referring to the web woven by people who intend to deceive others. The CFPB has created a “tangled web” while crafting regulations intended to prevent deception. This webinar will help you untangle the intricacies of numerous fee disclosure requirements.

The proper disclosure of fees on consumer loan transactions has always been complicated, take for example the multi-page calculation of a finance charge in §1026.4. Fee disclosure has become more complicated over the past few years with the addition and revisions of rules for:

  •     High-Cost Mortgages;
  •     Truth in Lending Act/Real Estate Settlement Procedures Act Integrated Disclosures (TRID);
  •     Ability to Repay/Qualified Mortgage Rules;
  •     Home Mortgage Disclosure Act/Regulation C; and
  •     The Military Annual Percentage Rate.

This program explains:

  •     Which fees are included in or excluded from the:
    •         Finance charge, per §1026.4 – The finance charge is a critical component in the calculation of the APR. Regulation Z provides a list of fees that are included in the finance charge and a list of fees that may be excluded, if certain conditions are met. Violations often occur when a fee is excluded from the finance charge but all of the conditions for the exclusion have not been met.
    •         Annual Percentage Rate (APR), per §1026.22 – The APR is based on the finance charge. Violations frequently occur when the finance charge is not properly calculated.
    •         Total Points and Fees, per §1026.32 – Jack has declared this number as “the most important number in the world of compliance.” It is used to determine coverage for Section 32 rules, it is disclosed in a Section 32 disclosure and on the HMDA LAR, and it is used to determine QM status under Section 43. A single miscalculation can result in multiple violations.
    •         Military Annual Percentage Rate (MAPR), per the Department of Defense’s §232 – Disclosure of the MAPR has been required since October 2007, but as a result of the limited scope of the rule most lenders have not needed to disclose the number. As a result of revisions to Part 232, effective October 3, 2016, the scope of the rule is dramatically expanded and most lenders will need to disclose the number. Although the calculation of the MAPR is similar to the calculation of an APR, differences generally result in a much higher number.
  •     The TRID Tolerance rules contained in §1026.19;
  •     The proper disclosure of fees on the Loan Estimate and Closing Disclosure, per §1026.37 and .38; and
  •     How some of these numbers impact a HMDA disclosure.

Please note that the program materials include a list of examples of specific fees outlined in the regulation.

The “Untangling the Web of Fee Disclosures” webinar has been approved for 2.5 CRCM credits. This statement is not an endorsement of this program or its sponsor. Credits are redeemable for Live attendance only. Certification holders must report these credits at https://aba.csod.com.

Covered Topics

  •   A violation of the finance charge rules contained in §1026.4 may also cause a violation of the disclosure requirements in §1026.18 or §1026.38 since the finance charge is included in those disclosures;
  •     Improper categorization of fees on the TRID disclosures contained in §1026.37 and .38 may result in a violation of the tolerance rules contained in §1026.19;
  •     Failure to follow the APR calculation rules contained in §1026.22 may result in:
    •         The incorrect APR appearing in the disclosures contained in §1026.18, §1026.32, §1026.37 or §1026.38;
    •         Inadvertently triggering coverage of §1026.32;
    •         An inaccurate calculation of the rate spread disclosed on the HMDA LAR and used to determine the applicability of the high-cost mortgage loan rules contained in §1026.32 and the higher-priced mortgage loan rules contained in §1026.35; or
    •         The incorrect disclosure of the HOEPA status disclosed on the HMDA LAR;
    •         An inaccurate determination of the higher-priced covered transaction status of a loan for purpose of determining which a transaction achieves safe harbor or presumption of compliance status for the ability to repay rules in Section 1026.43;
  •     Failure to properly calculate the total points and fees as prescribed by the high-cost mortgage loan rules contained in §1026.32 can:
    •         Inadvertently trigger §1026.32 coverage;
    •         Violate the disclosure rules contained in §1026.32;
    •         Result in an incorrect entry on the HMDA LAR; and
    •         Blow the Qualified Mortgage status for purposes of §1026. 43; or
  •     Failure to follow TRID rules contained in §1026.38 may result in the incorrect disclosure of the total of all itemized amounts that are designated borrower-paid at or before closing on HMDA LAR.

Who Should Attend?

This program is designed for everyone involved in the origination and management of consumer credit (including mortgage loans), including lenders, the compliance staff and auditors.

Continuing Education (CE) Credits

This webinar is recommended for 2.5 CE Credit Hours. Each attendee will receive a Certificate of Attendance for self-reporting of CE Credits.

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Related Topics

Instructor

Jack Holzknecht
Jack Holzknecht

Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 45 years. In 40 years as a trainer over 150,000 bankers (and many examiners) have part... read more.

Course TitleCreditsStart DateStart TimeDelivery TypeDelivery OptionInstructor / LocationPrice
Untangling the Web of Fee Disclosures Webinar0.25 Any AnyWebinarOn-Demand Jack Holzknecht$279.00 Register Now
Delivery Options

Webinars for Banks and Credit Unions

Live Webinar:

INCLUDES 30 DAYS OF ONDEMAND PLAYBACK! With this option, you will participate in the webinar (via the internet) as it is being presented. You will login to the webinar on your PC to view the PowerPoint presentation, and you have the option of using your PC speakers or a phone for the audio. You can type and send your questions to the instructor.  And don‰’t worry if you miss the webinar, you can still view it for up to thirty days after it takes place!

Live Plus Twelve Months OnDemand Playback:

With this option, you will receive the live version, then you will receive an e-mail that contains a link to the PowerPoint slides (to download, print, and copy) as well as a link where you will view and hear the entire webinar just as it was delivered, featuring the full-color PowerPoint presentation with audio. You can pause, fast-forward and rewind as needed, which makes it an effective training tool. The link will be available to you (and anyone else in the company) for up to twelve months and can be accessed 24/7 as many times as you wish. Delivered via e-mail the day after the webinar takes place.

Live, Twelve Months OnDemand Playback PLUS CD-ROM VIDEO:

By adding the CD-Rom to your order, you will have non- internet access to make the webinar part of your training library.  The CD-ROM Recording is a great option for viewing a webinar. You can pause, fast-forward and rewind as needed, which makes it an effective training tool. With this option, you will receive a download of the PowerPoint slides and a CD-ROM Recording (featuring PowerPoint presentation with audio) of the webinar via regular mail. Mailed 7 to 10 days after the webinar takes place.

Recorded Webinar Options available as Twelve Months OnDemand and Twelve Months OnDemand and CD-Rom

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