As you may recall, there are several criteria a bank must meet to determine whether it can originate Small Creditor Balloon Payment QMs and/or whether it is exempt from the HPML escrow requirement. One of these criteria, is the Service Area Test. This test requires that:
In the prior calendar year, more than 50% of your consumer purpose, closed-end, first-lien, dwelling-secured loans were secured by properties located in areas that are either “rural” or “underserved”.
The CFPB recently released a Rural and Underserved Areas Tool to help banks determine if properties are located in rural or underserved areas. The tool is pretty straight forward and user friendly. You just enter the year and the property address. You can also upload and search multiple addresses at one time. The questions and answers included with the tool also state, the tool provides a safe harbor determination that a specific property securing a mortgage loan is located in a rural or underserved area. For more information on the safe harbor, see 1026.35(b)(2)(iv)(C) and comment 35(b)(2)(iv)-1.iii.D.
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!