Dodd-Frank Still Being Ironed Out


Today we point you to this article in MarketWatch: “One Year On: Most Dodd-Frank changes still to come,” MarketWatch, July 21, 2011. (Click link to download PDF.) The 3 Wise Men disagree with this piece on two main points: 1. Regarding community and regional banks: Mr. Chris Cole’s comments generally make sense with the exception of the enormous regulatory requirements being imposed on the banking industry. The leaders of community banks with whom we have personally spoken are concerned their resources are inadequate to effectively function under the anticipated massive overkill of regulations coming out of Dodd-Frank, some of which have already been promulgated. It is our...

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Dodd-Frank: Your Questions Answered


Q: Is an escrow fee a prohibited payment to loan originators (MLB/MLO) in connection with a consumer credit transaction secured by a dwelling? A: It is our opinion, the phrase “…consumer credit transaction secured by a dwelling …” means a federally related residential mortgage loan transaction, i.e., a loan secured by 1 to 4 residential units, whether the principal residence of the borrower; whether for the purpose of purchasing, refinancing, or further encumbering the security property; and when the proceeds of the loan are used for personal, family, or household purposes, therefore the limitations of Dodd-Frank apply. Q: What if the MLB/MLO requires the use of a...

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