In a year that has proved to be more challenging than anyone could have anticipated, we are thankful and grateful for your business and loyalty. It has been our joy and privilege to serve you through this difficult time. We look forward to a time (hopefully) very soon when we can gather again with friends and families and enjoy the little things that make life gratifying. We wish you a Very Merry Christmas, the Happiest of Holidays, and a Prosperous New Year.
Mike Patterson and the PPDocs staff
PPDocs’ New 50(f)(2) Home Equity Rate/Term Refinance FAQs
Since January 1, 2018—when the Texas Constitution was amended to permit Section 50(f)(2) rate/term refinances of Texas 50(a)(6) home equity loans—we have received many questions regarding the various aspects of these refinances. To assist our clients in answering the questions we receive most often, we created a “Frequently Asked Questions” document. You can find it by navigating to our homepage, clicking on “Tools,” and then scrolling down the end of the “Home Equity” section to the document entitled: "F2 Rate/Term Refinance FAQs.” Alternatively, you can click this link: F2 Rate/Term Refinance FAQs
PPDocs 2021 Rescission Calendar
Our 2021 Rescission Calendar is now available on our website.
Texas Joint Financial Regulatory Agencies Finalize Home Equity Rule Changes
The Texas Joint Financial Regulatory Agencies adopted the home equity rule amendments we reported on in our August newsletter. The effective date of the adopted changes was November 26, 2020. The amendments are not significant and likely will not affect how you are currently operating. Here are our summaries of the amendments:
Texas Home Equity COVID-19 Emergency Measures Guidance Issued
The joint financial regulatory agencies (Department of Banking, Department of Savings and Mortgage Lending, Office of Consumer Credit Commissioner, and Credit Union Department) (Agencies) issued guidance on emergency measures for home equity lenders to consider in response to the COVID-19 pandemic. The guidance replaces the guidance published by the Agencies on April 22, 2020. The issuance includes guidance on:
- Advances on existing HELOC.
- When a lender may waive the one-year waiting period on a Section 50(a)(6) refinance and that Texas law does not permit waiving it it on a Section 50(f)(2) rate term refinance.
- Modifying a home equity loan.
- Authorized closing location.
If you have any questions after reading the guidance, please email us at firstname.lastname@example.org.
Federal Financial Institution Agencies Statement on LIBOR Transition
The Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation issued a statement encouraging banks to transition away from the U.S. Dollar LIBOR Index as soon as practicable and, in any event, by December 31, 2021, in order to facilitate an orderly—and safe and sound— LIBOR transition.
HPML Appraisal Threshold Unchanged for 2021
The Consumer Financial Protection Bureau, Comptroller of the Currency, and Federal Reserve Board have announced that, based on the Consumer Price Index for Urban Wage Earners and Clerical Workers in effect on June 1, 2020, the annual threshold amount for exempting loans from special appraisal requirements for higher-priced mortgage loans will remain at $27,200, effective January 1, 2021.
As part of a periodic review of our forms, we have decided to conform our Form SSA-89 more closely to the version promulgated by the Social Security Administration, and you will likely notice a change in format. The change is cosmetic; the material provisions of the form remain unchanged.
PPDocs 2020 Holiday Schedule
In observance of the upcoming holidays, our office will close at noon Christmas Eve and New Year’s Eve. Our office will be closed all day Christmas Day and New Year’s Day.
PPDocs 2021 Calendar
During 2021, our offices will be closed on: New Year’s Day, Memorial Day (May 31), Labor Day (September 6), and Thanksgiving Day (November 25). Our offices will close at noon on Christmas Eve and New Year’s Eve.
December’s Frequently Asked Question
Question: We have a number of questions regarding how holidays affect TRID: When may we close on an initial CD delivered on a holiday? May we close on a holiday? How do we count the three-day waiting period after the initial CD when closing on a holiday? When Friday is an observed holiday for a weekend holiday, is Friday considered a holiday or a business day?
Answer: Our new “Frequently Asked Questions About Holidays” resource answers all four of these questions. If you have any other holiday lending questions, please let us know.