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Untangling the Web of Fee Disclosures

This webinar will help you untangle the intricacies of numerous fee disclosure requirements.

OnDemand
Recorded Wednesday,
April 13th, 2022
Presented by Jack Holzknecht
2h total length
2.5 CRCM Credits
$279.00 or 1 Token

Includes: 30 Days OnDemand Playback, Presenter Materials and Handouts

  • Compliance
  • Lending
  • Bank Legal Counsel
  • Board Member
  • Compliance Officer
  • Consumer Lender/Retail Banker
  • Loan Closer
  • Mortgage Lender
  • Trainer

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"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.

What You'll Learn

  • 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.

Jack Holzknecht

Instructor Bio

Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 44 years. In 39 years as a trainer over 147,000 bankers (and many examiners) have participated in Jack's live seminars and webinars. Jack's career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by a number of state bankers associations. As a contractor, he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.

Continuing Education Credit Information

Untangling the Web of Fee Disclosures has been approved for 2.5 CRCM credits. This statement is not an endorsement of this program or its sponsor. Credits are redeemable for both Live and OnDemand viewing. For questions on certificates, please email support@oncourselearning.com. Certification holders must report these credits at https://aba.csod.com.

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