Homebridge makes the agreement available to the borrower (s) for all loans blocked after presentation. The NDC/EB is still responsible for making the agreement available to borrowers within three (3) working days following the interest rate freeze and providing a copy of the agreement signed to Homebridge. The proposed amendments, which affect MLOs, include additional advertising obligations with respect to interest rate bans. Under the proposed amendments, MLOs must re-lock interest rates to a borrower within three business days of an interest-related change. Valid reasons for changing a blocked interest rate include changes in the value of the credit, credit valuation or other factors that may have a direct impact on pricing. The amendments will also allow MLOs to take out an advance penalty or a fee for a variable rate residential loan, provided that “the penalty or fee expires at least sixty days before the initial reoccentation period.” The amendments include that a credit processor may use files from an unauthorized storage location, provided that the processor accesses files directly from the licensed mortgage broker`s main computer system, that it does not perform any of the activities of a licensed MLO, and that the authorized MLO has protective measures to protect borrowers` information. The State of Washington requires borrowers to receive disclosure of the Lock Agreement Rate within three (3) business days from the date the interest rate is locked. The proposed amendments also include several amendments for student loan service providers, which are governed by the Consumer Credit Act, including: (i) licensees who provide student loans to borrowers in the state “may ask the director to forego or adjust the annual amount of the investment”; (ii) licensees are required to disclose their rights to all service members in accordance with the laws and regulations of members of the state and the federal government with respect to their student loans; and (iii) student loan fellows must review all student loan borrowers using the Ministry of Defence database to ensure that borrowers` rights are properly enforced and maintain written policies and procedures for this practice. The proposed amendments also indicate that compliance with federal law is sufficient to meet several Washington requirements applicable to student loan service providers, including borrower payment rules. The above directive applies to loans submitted to Homebridge on May 20, 2019 or after May 20, 2019. If you have any questions, please contact your Account Executive. “ACC Newsstand is another useful, tailored and easily accessible resource that directly coincides with our focus on time, money and effort for CCA members.” On September 24, the State Department of Financial Institutions of Washington (DFI) will hold a hearing on the order motions to discuss changes to mortgage originators (MLOs) and provisions for student credit providers. The proposed amendments will amend the rules affecting the Washington Consumer Loan Act and the Student Brokerage Practices Act, including those relating to the regulation of student loan service providers as part of a final rule that came into effect on January 1.
(See the previous info-byte report on the DFI`s acceptance of changes to student loan service providers here.) According to the DFI, the proposed amendments are expected to come into effect on November 24. A copy of the AV Rate lockout agreement is attached as a reference and is also published on Homebridge`s website at www.homebridgewholesale.com address on the broker resources page under disclosures required by state, Washington.