Well, folks, I think you all should read the attached. The CFPB went public with its four primary audit areas, beyond the normal ones disclosed in our Books One, Two, and Three.
- COMP PLANS, and yes, looking backwards two or three years as well.
- TRID, with no grace period.
- MSAs, nothing here to be said. They can be done legally, but it takes a lot of work and commitment by all involved to steer clear of RESPA Violations.
- ATR – yes, that pesky part of your QM Policy in Book One. They will evaluate your use of some form of proper ATR test.
No where did they mention exempting anyone from these four areas. No special favors for private money lenders who lend against 1-4 family etc. So, please read the attached.
We still have time to get you set up for the end of this year. Where compliance is involved, sooner is better. Later is foolish. You can reach us at (800) 656-4584 and we will get to work right away!
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