Rules in June 2025 Release

Federal

ECS has been updated to include additional detailed messaging in new PASS and FAIL status messages with dynamic messaging for Rule Header 1001382 Federal - Loan Estimate Received At Least Four Business Days Before Consummation (BLD), Rule Header 1001383 Federal - Loan Estimate Disclosure Date on or after Closing Disclosure Date (BLD), and Rule Header 1001386 Federal - Prior Loan Estimate Received At Least Four Business Days Before Consummation (BLD), under certain circumstances.

Federal - Loan Estimate Received At Least Four Business Days Before Consummation (BLD)

Last Loan Estimate Sent Method In Person and No Received Date (Disclosure Level)(1001382)

A revised Loan Estimate was provided to the consumer in person on (yyyy-mm-dd), which is at least four business days prior to the consummation date of (yyyy-mm-dd). Four business days before consummation is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate not later than four days prior to consummation of the transaction. (12 CFR 1026.19(e)(4)(ii))

Last Loan Estimate Sent Method In Person and No Received Date (Disclosure Level)(1001382)

A revised Loan Estimate was provided to the consumer in person on (yyyy-mm-dd), which is not four business days prior to the consummation date of (yyyy-mm-dd). Four business days before consummation is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate not later than four days prior to consummation of the transaction. (12 CFR 1026.19(e)(4)(ii))

Last Loan Estimate Sent Method Not In Person and No Received Date (Disclosure Level)(1001382)

A revised Loan Estimate was provided or mailed on (yyyy-mm-dd). Since it was provided via (yyyy-mm-dd), a consumer is considered to have received it on (yyyy-mm-dd), which is at least four business days prior to the consummation date of (yyyy-mm-dd). Four business days before consummation is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate not later than four business days prior to consummation. If the revised Loan Estimate is not provided to the consumer in person, the consumer is considered to have received the revised Loan Estimate three business days after the creditor delivers or places such version in the mail. (12 CFR 1026.19(e)(4)(ii))

Last Loan Estimate Sent Method Not In Person and No Received Date (Disclosure Level)(1001382)

A revised Loan Estimate was provided on (yyyy-mm-dd) via (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate not later than four business days prior to consummation date of (yyyy-mm-dd). Since the revised Loan Estimate was not provided in person, a consumer is considered to have received it on (yyyy-mm-dd), which is three business days after it was delivered or placed in the mail. As a result, the revised Loan Estimate is not deemed to have been received at least four business days before consummation, which is (yyyy-mm-dd). (12 CFR 1026.19(e)(4)(ii))

Last Loan Estimate Received Date and Consummation Date (Disclosure Level)(1001382)

The last Loan Estimate Received Date of (yyyy-mm-dd) is at least 4 business days before the consummation date of (yyyy-mm-dd). Four business days before consummation date is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate no later than 4 business days before consummation. (12 CFR 1026.19(e)(4)(ii))

Last Loan Estimate Received Date and Consummation Date (Disclosure Level)(1001382)

The last Loan Estimate Received Date of (yyyy-mm-dd) is not 4 business days before the consummation date of (yyyy-mm-dd). Four business days before consummation is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate no later than 4 business days before consummation. (12 CFR 1026.19(e)(4)(ii))

Last Loan Estimate Sent Method Not In Person and No Received Date (Disclosure Level)(Preview)(1001382)

You selected a compliance Preview analysis. A revised Loan Estimate was provided or mailed on (yyyy-mm-dd). Since it was provided via (yyyy-mm-dd), a consumer is considered to have received it on (yyyy-mm-dd), which is at least four business days prior to the consummation date of (yyyy-mm-dd). Four business days prior to consummation is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate not later than four business days prior to consummation. If the revised Loan Estimate is not provided to the consumer in person, the consumer is considered to have received the revised Loan Estimate three business days after the creditor delivers or places such version in the mail. (12 CFR 1026.19(e)(4)(ii))

Last Loan Estimate Sent Method Not In Person and No Received Date (Disclosure Level)(Preview)(1001382)

You selected a compliance Preview analysis. A revised Loan Estimate was provided on (yyyy-mm-dd) via (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate not later than four business days prior to the consummation date of (yyyy-mm-dd). Since the revised Loan Estimate was not provided in person, a consumer is considered to have received it on (yyyy-mm-dd), which is three business days after it was delivered or placed in the mail. As a result, the revised Loan Estimate is not deemed to have been received at least four business days before consummation, which is (yyyy-mm-dd). (12 CFR 1026.19(e)(4)(ii))

Federal - Loan Estimate Disclosure Date on or after Closing Disclosure Date (BLD)

Last Loan Estimate and Closing Disclosure (Disclosure Level)(1001383)

The Last Loan Estimate was provided on (yyyy-mm-dd) which is before (yyyy-mm-dd), the date on which the Initial Closing Disclosure was provided. Under Regulation Z, a creditor shall not provide a revised version of the Loan Estimate on or after the date on which a creditor provides the Closing Disclosure. (12 CFR 1026.19(e)(4)(ii))

Last Loan Estimate and Closing Disclosure (Disclosure Level)(1001383)

The Last Loan Estimate was provided on (yyyy-mm-dd) which is on or after (yyyy-mm-dd), the date on which the Initial Closing Disclosure was provided. Under Regulation Z, a creditor shall not provide a revised version of the Loan Estimate on or after the date on which a creditor provides the Closing Disclosure. (12 CFR 1026.19(e)(4)(ii))

Federal - Prior Loan Estimate Received At Least Four Business Days Before Consummation (BLD)

Prior Loan Estimate Sent Method In Person and No Received Date (Disclosure Level)(1001386)

A revised Loan Estimate was provided to the consumer in person on (yyyy-mm-dd), which is at least four business days prior to the consummation date of (yyyy-mm-dd). Four business days before consummation is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate not later than four days prior to consummation of the transaction. (12 CFR 1026.19(e)(4)(ii))

Prior Loan Estimate Sent Method In Person and No Received Date (Disclosure Level)

A revised Loan Estimate was provided to the consumer in person on (yyyy-mm-dd), which is not four business days prior to the consummation date of (yyyy-mm-dd). Four business days before consummation is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate not later than four days prior to consummation of the transaction. (12 CFR 1026.19(e)(4)(ii))

Prior Loan Estimate Sent Method Not In Person and No Received Date (Disclosure Level)(1001386)

A revised Loan Estimate was provided or mailed on (yyyy-mm-dd). Since it was provided via (yyyy-mm-dd), a consumer is considered to have received it on (yyyy-mm-dd), which is at least four business days prior to the consummation date of (yyyy-mm-dd). Four business days before consummation is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate not later than four business days prior to consummation. If the revised Loan Estimate is not provided to the consumer in person, the consumer is considered to have received the revised Loan Estimate three business days after the creditor delivers or places such version in the mail. (12 CFR 1026.19(e)(4)(ii))

Prior Loan Estimate Sent Method Not In Person and No Received Date (Disclosure Level)(1001386)

A revised Loan Estimate was provided on (yyyy-mm-dd) via (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate not later than four business days prior to the consummation date of (yyyy-mm-dd). Since the revised Loan Estimate was not provided in person, a consumer is considered to have received it on (yyyy-mm-dd), which is three business days after it was delivered or placed in the mail. A consumer must receive a revised Loan Estimate not later than four business days prior to consummation. Four business days before consummation is (yyyy-mm-dd). (12 CFR 1026.19(e)(4)(ii))

Prior Loan Estimate Received Date and Consummation Date (Disclosure Level)(1001386)

The prior Loan Estimate Received Date of (yyyy-mm-dd) is at least 4 business days before the consummation date of (yyyy-mm-dd). Four business days before consummation is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate no later than 4 business days before consummation. (12 CFR 1026.19(e)(4)(ii))

Prior Loan Estimate Received Date and Consummation Date (Disclosure Level)(1001386)

The prior Loan Estimate Received Date of (yyyy-mm-dd) is not at least 4 business days before the consummation date of (yyyy-mm-dd). Four business days before consummation is (yyyy-mm-dd). Under Regulation Z, a consumer must receive a revised Loan Estimate no later than 4 business days before consummation. (12 CFR 1026.19(e)(4)(ii))

CER-25120

State Rules

Alaska

ECS has been updated to include logic analyzing whether the loan’s interest rate exceeds the greater of 10% or the applicable index plus 5% in the Alaska SAFE Act's mortgage lender and mortgage broker license applicability rule. This update aligns with Alaska Statute § 45.45.010(b), which sets the maximum annual interest rate at the greater of 10% or 5 percentage points above the annual rate charged member banks for advances by the 12th Federal Reserve District on the day on which the contract or loan commitment is made.

CER-25274

California

ECS has been updated to include fees paid by the Mortgage Broker in the California Covered Loan (High Cost) points and fees calculation, if those same fees had been paid by the Borrower.

CER-25225

Indiana

ECS has been updated to reflect the new nonrefundable prepaid finance charge threshold for Indiana junior lien loans, as outlined in the Indiana Uniform Consumer Credit Code (IC 24-4.5-3-201(9)). Effective July 1, 2025, the threshold increases from 2% to 3% for loans secured by an interest in land, regardless of whether they are made under a revolving loan account or not.

A new Pass and Alert status message will be returned depending on if the prepaid finance charge exceeds the threshold for the applicable time frame or not.

Consummation Date Threshold Percentage Does Not Exceed Threshold Exceeds Threshold
Prior to July 1, 2025 2% Pass Alert
On or after July 1, 2025 3% Pass Alert

The following rules are affected by this change:

  • Nonrefundable Prepaid Finance Charge (2% Threshold)(Closed End)
  • Nonrefundable Prepaid Finance Charge (2% Threshold)(HELOC)
  • Nonrefundable Prepaid Finance Charge (3% Threshold)(Closed End)
  • Nonrefundable Prepaid Finance Charge (3% Threshold)(HELOC)

CER-25181

Iowa

In the May 2025 Rules Release, ECS was updated to consider whether fees are paid by the seller and identified as seller-obligated under RH 1001480 Iowa - Fees Not Allowed (535.8(4)(b)). The update returned either a Pass or Fail status message, depending on the existence of such fees.

In this release, ECS has updated this rule to reflect your selection if you had previously selected (through service code parameter) to receive a WARNING status message for RH 1001480.

CER-25258

ECS has been updated to exclude both Home Warranty Premium and Temporary Buydown Fee from the fees not allowed under Iowa Code 535.8(4)(b), affecting Iowa loans submitted to the system.

The changes are being made because:

  • The Home Warranty Premium is an optional service/product the buyer voluntarily chooses to purchase and is not required by the lender. It is not a charge connected to the loan.
  • The Temporary Buydown Fee is the amount prepaid by the borrower, seller, lender, broker or other that reduces the monthly payment amount for a specified period of time at the beginning of the scheduled payment period.

When the Home Warranty Premium or Temporary Buydown Fee is charged to the borrower, a Fail status message will no longer be returned under Section 535.8(4)(b). Instead, the review will be processed as normal.

The following rule header is affected by this change:

  • RH 1002984 Iowa - Fees Not Allowed (535.8(4)(b))

Home Warranty Premium — Cost of home warranty insurance used to repair or replace items and major systems in the subject property which break down through normal wear and tear, including but not limited to: electrical, plumbing, sewage disposal, HVAC systems, permanently installed appliances, drainage and grading, exterior finishes, decks, porches, attics, insulation, smoke and fire detectors, and ventilation systems. Warranty is not required by the creditor.

Temporary Buydown Fee — Charge to reduce the interest rate on the loan for a given period.

CER-25267, CER-25298

ECS has been updated to include a new rule that prohibits discount points under the Iowa Uniform Consumer Credit Code (IC 537.2501(1)(e)(6)) if the points and fees exceed the Federal Qualified Mortgage loan threshold for loans with a consummation date on or after July 1, 2025.

A new Pass and FAIL status message will be returned if discount points are charged to the borrower and the points and fees exceed the Federal Qualified Mortgage loan threshold.

Consummation Date QM Loan Threshold Does Not Exceed Threshold Exceeds Threshold
On or after July 1, 2025 $71,900 Pass Fail

The following rule header is affected by this change:

  • RH 1001499 - Discount Points Not Allowed

Iowa - Discount Points Not Allowed

Discount Points Not Allowed if QM Points and Fees Exceeded

This loan includes ($_) in Discount Points and the points and fees do not exceed the QM loan threshold. The Iowa Consumer Credit Code prohibits discount points if the points and fees exceed the QM loan threshold. (Iowa Code 537.2501(1)(e)(6))

Discount Points Not Allowed if QM Points and Fees Exceeded

This loan includes ($_) in Discount Points and the points and fees exceed the QM loan threshold. The Iowa Consumer Credit Code prohibits discount points when the points and fees exceed the QM loan threshold. (Iowa Code 537.2501(1)(e)(6))

CER-25279

North Carolina

ECS has been updated to include additional detailed information in the existing PASS and FAIL status messages under Rule Header 26390 North Carolina - Max Lender Fees and Rule Header 26400 North Carolina - Max Lender Fees (Banks).

North Carolina - Max Lender Fees

Lender Fees Must Be <= 2% of Loan(26390)

This loan contains in ($_) in origination fees, which includes all fees paid to lender, excluding prepaid interest and impounds. Under the North Carolina Interest Provisions, on a junior lien loan less than $300,000, the lender may not charge origination fees exceeding 2% of the loan amount. (N.C. Gen. Stat. 24-10)

Lender Fees Must Be <= 2% of Loan(26390)

This loan contains in ($_) in origination fees, which includes all fees paid to lender, excluding prepaid interest and impounds. Under the North Carolina Interest Provisions, on a junior lien loan less than $300,000, the lender may not charge origination fees exceeding 2% of the loan amount which is ($_). (N.C. Gen. Stat. 24-10)

Lender Fees Must Be <= 1% of Loan(26390)

This loan contains in ($_) in origination fees, which includes all fees paid to lender, excluding prepaid interest and impounds. Under the North Carolina Interest Provisions, on a first lien HELOC less than $300,000, the lender may not charge origination fees exceeding 1% of the loan amount. (N.C. Gen. Stat. 24-10)

Lender Fees Must Be <= 1% of Loan(26390)

This loan contains in ($_) in origination fees, which includes all fees paid to lender, excluding prepaid interest and impounds. Under the North Carolina Interest Provisions, on a first lien HELOC less than $300,000, the lender may not charge origination fees exceeding 1% of the loan amount which is ($_). (N.C. Gen. Stat. 24-10)

North Carolina - Max Lender Fees (Banks)

Lender Fees Must Be <= 2% of Loan(26400)

This loan contains in ($_) in origination fees, which includes all fees paid to lender, excluding appraisal fee, appraisal review fee, appraisal desk review fee, appraisal field review fee, prepaid interest and impounds. Under the North Carolina Interest Provisions, on a junior lien loan, the lender may not charge origination fees exceeding 2% of the loan amount. (N.C. Gen. Stat. 24-10)

Lender Fees Must Be <= 2% of Loan(26400)

This loan contains in ($_) in origination fees, which includes all fees paid to lender, excluding appraisal fee, appraisal review fee, appraisal desk review fee, appraisal field review fee, prepaid interest and impounds. Under the North Carolina Interest Provisions, on a junior lien loan, the lender may not charge origination fees exceeding 2% of the loan amount which is ($_). (N.C. Gen. Stat. 24-10)

Lender Fees Must Be <= 1% of Loan(26400)

This loan contains in ($_) in origination fees, which includes all fees paid to lender, excluding appraisal fee, appraisal review fee, appraisal desk review fee, appraisal field review fee, prepaid interest and impounds. Under the North Carolina Interest Provisions, on a first lien loan, the lender may not charge origination fees exceeding 1% of the loan amount. (N.C. Gen. Stat. 24-10)

Lender Fees Must Be <= 1% of Loan(26400)

This loan contains in ($_) in origination fees, which includes all fees paid to lender, excluding appraisal fee, appraisal review fee, appraisal desk review fee, appraisal field review fee, prepaid interest and impounds. Under the North Carolina Interest Provisions, on a first lien loan, the lender may not charge origination fees exceeding 1% of the loan amount which is ($_). (N.C. Gen. Stat. 24-10)

CER-25150

Virginia

ECS has been updated to exclude Attorney's Fees - Borrower's Attorney from the fees not allowed under Virginia Code Ann. § 6.2-328, affecting Virginia junior lien loans submitted to the system subject to this provision. This change is being made to align with Virginia Code Ann. § 6.2-328, which states that any lender making a loan secured by a subordinate mortgage or deed of trust may require the borrower to pay certain fees, including attorney fees.

When Attorney's Fees - Borrower's Attorney is charged to the borrower, a FAIL status message will no longer be returned. Instead, the review will be processed as normal.

The following rule header is affected by this change:

  • RH 8080 Fees Not Allowed (Junior Liens)

Attorney's Fees - Borrower's Attorney — General uncategorized fees paid to the borrower’s attorney for services rendered in connection with the loan. Same type of fee described in the Attorney’s Fees description, but for which the Borrower hires its own attorney to represent the Borrower's interests. The attorney is not required by the creditor, nor is the attorney from an approved lender list, for which a borrower has been provided with a choice of attorney.

CER-25197

Multi-State Rules

ECS has been updated to include an INFO status message for specific Escrow/Impound rules in the District of Columbia, Iowa, Oregon, Utah, and Vermont, replacing the previous WARNING status message. The Warning status message has been removed.

The following rule headers are affected by this change:

District of Columbia

  • RH 14870 Escrow/Impound of Property Tax/Insurance Premiums Limitation (Junior Liens)
  • RH 1000019 Escrow/Impound of Property Tax/Insurance Premiums Limitation (Junior Liens)(Dual License)
  • RH 14850 Escrow/Impound of Property Tax/Insurance Premiums Limitation

Iowa

  • RH 17040 Escrow/Impound Warning
  • RH 23720 Escrow/Impound Warning (Savings)

Oregon

  • RH 9070 Escrow/Impound Fees Warning

Utah

  • RH 9020 Escrow/Impound Property Insurance Warning

Vermont

  • RH 22410 Property Taxes/Insurance Warning
  • RH 22410 Property Taxes/Insurance Warning (07/17)

CER-25193

Current Section

Current Section

Rules in June 2025 Release