Title Insurance Agency Compliance Tag Archives

The Federal Housing Administration “FHA” published Mortgage Letter (ML) 2022-22 on December 15, 2022, which provides new clarifications on its Conflicts of Interest Policy and Dual Employment Policy for most Title II Single Family FHA-Insured Mortgage Transactions.

The new Mortgage Letter revisions have taken a dramatic change in that FHA Policy now permits individuals who do not have a “direct impact on the mortgage approval decision” to have various compensated positions for services performed and allowed by the Department of Housing and Urban Development “HUD”, provided that the transaction complies with all applicable federal, state, and local laws, rules, and requirements.

The 2022-22 Mortgage Letter now consolidates various conflicts of interest and dual employment subsections in the Single-Family Housing Policy Handbook 4000.1 into one subsection and provides clarification on FHA policy regarding prohibited conflicts of interest by individuals that directly impact the mortgage approval decision and permitted dual employment for other individuals who perform services in a single FHA-insured transaction. FHA believes the policy consolidation and clarification will help facilitate an easier understanding of existing FHA requirements given feedback from the real estate industry and from confusion internally at FHA with how to apply the past Policy.

Marx Sterbcow, the Managing Attorney at the Sterbcow Law Group, will be speaking at the National Settlement Services Summit in Orlando, Florida with Kris Kully, Partner at Mayer Brown, along with moderator Tracey Read, Editor of RESPA News. The session “RESPA Step by Step” will discuss the step-by-step process of how to properly structure affiliated business arrangements from start to finish. The presentation will talk about the important issues in the operating agreement to operation compliance concerns to what the CFPB and state regulators want and don’t want when they are looking at these types of arrangements. The presentation is from 11:20-12:10 AM in the International Ballroom. NS3 is considered the premier annual conference in the real estate settlement services industry. The conference is being held at the Omni Orlando Resort at Champions Gate.

Articles Tagged with Title Insurance Agency Compliance

The Federal Housing Administration Revises Dual Employment Requirements and Clarifies Conflict of Interest Policies

Marx Sterbcow speaking at The National Settlement Services Summit (“NS3”) on June 2, 2022 in Orlando, Florida.