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Posts Tagged ‘home loans’

MHI 2013 Annual Meeting Recap

October 10th, 2013 No comments

IMHA Executive Director Mark Bowersox attended the Manufactured Housing Institute’s (MHI) annual meeting held September 28 – October 1 in Carlsbad, CA. As with most recent industry meetings, speakers and conversations at the event were focused on the impact of the Dodd-Frank consumer protection legislation and reforming the CFPB’s upcoming regulations. MHI and other industry representatives continue to work with the CFBP on three key areas:

Exemption for manufactured housing appraisal requirements

Based on the most recent rules issued by the CFPB loans on all new manufactured homes, regardless of whether or not they included land, are exempt from the appraisal requirement. Loans on existing manufactured homes, not including land, are also exempt from the appraisal requirements. Additionally, all mobile homes (pre-HUD code) home loans are exempt. The CFPB’s rule solidifying these exemptions is still pending. When finalized the rule will go into effect in January.

Key rule clarifications and exclusions

Loan originator compensation guidelines issued by the CFPB this summer provide the industry with key exclusions from the points and fees calculation that lenders must perform and clarifies certain activities that retail sales staff can engage in without being defined as loan originators.

Manufactured home sales price is excluded from the points and fees definition and does not have to be included in calculations performed by lenders unless a creditor has knowledge that the sales price includes compensation for loan origination activities.

 

Retail sales commissions paid to employees is excluded from points and fees calculation requirements unless the salesperson is receiving compensation from a lender for loan origination activities.

According to MHI, activities that do not classify a retailer or its sales personnel as loan originators include:

  • Providing or making available general information about creditors and loan originators that may offer financing for manufactured housing
  • Gathering or collecting supporting information or documentation on behalf of a consumer for inclusion in a credit application
  • Providing general credit application instructions so that a consumer can complete it themselves
  • Financing the sale of no more than three homes in a year.

Activities that will make a retail employee be considered a loan originator include:

  • Filling out a credit application for a customer
  • Discussing particular credit terms with a customer
  • Directing or influencing a customer to select a particular lender or creditor

MHI continues to seek from the CFPB to provide further clarification on what activities retailers can engage in without being defined as loan originators.

MHI is still working with the CFPB and various consumer interest groups on the need to revise the upcoming High Cost Mortgage Loan triggers for manufactured home loans. IMHA will continue to be engaged on this issue, along with MHI and other interested parties. ##

mark-bowersox-imha-posted-industry-voices-guest-blog-mhpronews.com-75x75pxl-.pngMark Bowersox
Executive Director
Indiana Manufactured Housing Association
Recreation Vehicle Indiana Council
3210 Rand Road
Indianapolis, IN  46241

(Editor's Note: You can find more info on the LO Comp Rule and HOEPA from DJ Pendelton's article published in the Industry In Focus Reports module, linked here.

 

You can also find Mark Bowersox's “It's Now or Never” featured article, linked here. )

Act Today to Preserve Manufactured Housing Lending!

September 4th, 2013 No comments

Our congressional delegation will be heading back to Washington DC soon after being in their districts for most of August. If you haven’t already done so, please contact your elected Representative today about the harmful impact new financial regulations will have when they go into effect.

The primary focus of our industry nationwide is to remove harmful provisions in federal financing and consumer protection law that are set to begin in mid-January.

One of the primary issues is the fact that industry lenders could be held responsible for the discussions and actions of salespeople on retail lots and in communities.

The other issue is government restrictions on how high interest rates can be for home loans. Manufactured housing loans are usually lower balances and shorter terms than site-built housing which causes the rate caps to be restrictive.

Some manufactured housing lenders are considering exiting the business if these provisions are allowed to take effect and this clearly is something the industry cannot afford.

The industry is attempting to amend these harmful regulations out of federal law before they go into effect in January. HR 1779, the “Preserving Access to Manufactured Housing Act” was introduced in the United States House of Representatives and currently has more than 60 co-sponsors. The Manufactured Housing Institute estimates we need about 120 co-sponsors nationally in order to move this legislation.

We need your help!

So far, two of Indiana’s nine Representatives have signed on as co-sponsors of this legislation – Congressman Marlin Stutzman and Congresswoman Jackie Walorski – and we need more support.

The current House recess is a good opportunity to contact your elected Representative to discuss the legislation is critical to Indiana jobs, our industry and your business. Get with your state association and/or MHI to see what are the best wasy that you can team up with others to move this into a win column for our industry. ##

mark-bowersox-indiana-manufactured-housing-association-rvic-posted-mhpronews-com75x75-Mark Bowersox
Executive Director
Indiana Manufactured Housing Association – Recreation Vehicle Indiana Council
 

Action Alert: Don’t Let Lending for New Homes Dry Up on January 1, 2014!

June 12th, 2013 No comments

IN A NUTSHELL: If we do not get legislative changes this year, loans for home buyers could be EVEN LESS available afterJanuary 1, 2014.Yes, it can get even worse if we do nothing. Please help us by doing two things

1. Contact your Member of Congress to express your support for H.R. 1779 (information is below).

2. Please go to cosponsor.gov(http://cosponsor.gov/details/hr1779-113) and express your support for H.R. 1779 (you need to have a Facebook account use cosponsor.gov).

BACKGROUND: We have encouraged VAMMHA members and others who read this to contact members of their Congressional Delegation to ask them to cosponsor H.R. 1779. Members in the 5th District of Virginia are encouraged to contact Congressman Robert Hurt (who has already agreed to cosponsor the bill) to thank him for his support.

Here is what this issue is about: Reps. Stephen Fincher (R-TN), Bennie Thompson (D-MS) and Gary Miller (R-CA) have introduced thePreserving Access to Manufactured Housing Act(H.R. 1779).

The measure would amend provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act that would otherwise curtail the availability of credit needed by those seeking to purchase manufactured housing if action isn't taken..

Specifically, the bill would revise the High-Cost Mortgage triggers for manufactured home loans, and make clarifications to the Loan Originator definition as it applies to manufactured home retailers and salespeople.

These two areas of the law—which are scheduled to become effective January 2014—would substantially reduce lender ability to originate manufactured home loans.

Assistance is needed from VAMMHA members and others within the manufactured housing industry, in contacting their Representatives to request they co-sponsor H.R 1779.

More details are available in thisdetailed issue brief/action alert.

Here is what we need: Please take a moment to contact your House member and ask them to cosponsor H.R. 1779.

To help you out,here is a sample letter that can be faxed or cut and pasted into an email to Congressional offices.

If you need to look up your Member of Congress, please click herehttp://www.house.gov/representatives/find/.

IMPORTANT: Congressman Robert Hurt (5th Congressional District) has agreed to cosponsor this bill. So, if he is your Congressman, instead of using the sample letter, please contact him to thank him for his support.

The following resource information is also available:

Over the coming weeks, Sen. Sherrod Brown (D-OH) is expected to introduce companion legislation in the Senate. Additional information will be provided at that time.

Please be sure to share with us any feedback you get from your Member of Congress. Thank you for all that you do to support the factory-built housing industry in Virginia.

tyler-craddock-executive-director-virginia-manufactured-and-modular-housing-associationTyler Craddock, Executive Director
Virginia Manufactured and Modular Housing Association
8413 Patterson Avenue
Richmond, Virginia 23229
Office804.750.2500
Mobile804.980.1172
Fax804.741.3027
Emailtcraddock@vammha.org