In California, MRG now provides a completed document to satisfy the California Department of Corporations' requirement to supply a Nontraditional Lending Disclosure when a loan is considered a nontraditional product. When the property is located in California and the selected product is either an interest-only or option/negative amortization adjusted rate mortgage, a new screen titled “CA additional programs" is available for users to select up to ten additional loan programs offered by the lender.
Additional programs are used to calculate values that populate the disclosure included in the document package. MRG's system calculates results using the lender's products and terms as specified in MIRACLE and as required by the regulation. The document is not static and does not include predetermined products and calculations.
In Maine, MIRACLE now includes a screen for completion of the Maine Reasonable, Net Tangible Benefit Disclosure. For refinance transactions in Maine, lenders can complete the disclosure on the “related lien” screen.
“As states announce new lending regulations to reflect current market conditions, MRG’s systems continue to evolve,” said Terry King, group Chairman of MRG. “MRG understands that mortgage brokers and lenders require customizable tools that fit their current loan products and comply with state requirements and borrowers' needs, and we provide a flexible system to meet those requirements.”
Most mid-tier lenders have fallen back on the document vendors to provide built-in compliance services, though many competitors don't have internal compliance attorneys on staff. This is an area of high concern for lenders in an environment of increased scrutiny, overlapping jurisdictions and additional legal complexity. (I could have just said "scariest environment possible" I guess).
MRG is the mortgage document practice group within Middleberg Riddle & Gianna, a mortgage regulatory law firm.