S.R. Snodgrass, A.C.
Certified Public Accountants
and Consultants
and Consultants
11/2009 – Compliance Update
By S.R. Snodgrass Outsourcing Group
Regulation CC Non-Local Checks; Changes in “Insurable Value” for Flood Insurance Purposes; Promp Crediting of Mortgage Loan Payment Changes to Regulation Z; HUD Provides More Guidance to the 1/1/10 CFE and HUD-1 Changes
HIGHER-PRICED MORTGAGE LOANS (HPML) AND BALLOON PAYMENTS
Regulation Z changes that were effective October 1, 2009, created a dilemma regarding how a lender can satisfy the requirement to assess the borrower’s ability to repay an HPML when the loan involves a balloon note with a term of less than seven years. No guidance had been given on how a lender could determine the borrower’s ability to repay the balloon payment.
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