Rules in March 2025 Release
Enterprise
VA 1% Unallowable Fees Test Updated to Allow Pest Inspection Fee for Certain States (and Counties) Under Rule Header 1001276 Federal - VA Loan Origination and Other Restricted Fees
04/01/2025
For loans with a consummation date on or after June 15, 2022, the VA 1% worksheet will exclude Borrower paid Pest Inspection Fee (Fee ID 72) in the following states and counties (if applicable):
- Michigan—Allegan, Barry, Berrien, Branch, Calhoun, Cass, Hillsdale, Ionia, Jackson, Kalamazoo, Kent, Lenawee, Livingston, Macomb, Mason, Monroe, Muskegon, Oakland, Oceana, Ottawa, St. Clair, St. Joseph, VanBuren, Washtenaw and Wayne counties
- Nebraska
- New Hampshire—Cheshire, Sullivan, Merrimack, Rockingham, Belknap, Hillsborough, and Strafford counties
- New York—Bronx, Broome, Columbia, Delaware, Dutchess, Greene, Kings, Nassau, New York, Orange, Putnam, Queens, Richmond, Rockland, Suffolk, Sullivan, Ulster and Westchester counties
- Pennsylvania
- Utah
- Vermont—Bennington and Windham counties
- Wisconsin—Columbia, Crawford, Dane, Dodge, Grant, Green, Iowa, Jefferson, Kenosha, Lafayette, Milwaukee, Ozaukee, Racine, Richland, Rock, Sauk, Vernon, Walworth, Washington, and Waukesha counties
For more information about the Department of Veterans Affairs policies regarding wood destroying pest inspection fees and repair costs, refer to VA Circular 26-22-11.
CER-24588
Federal
New WARNING Status Message When Loan Disbursement Date is Missing Under the TILA-ROR Review
Federal - Right of Rescission Variance Warning (TILA)
Right of Rescission Variance Warning (TILA) CD Sent after Consummation Date (Loan Disbursement Date Missing)(1000865)
You did not provide a Loan Disbursement Date and the Last Closing Disclosure (_) was sent after Consummation, so the system assumes the CD with the "material disclosures" was provided before or on the (_) Consummation Date. The system cannot run any rescission tests without a Loan Disbursement Date. A "consumer" may exercise the right to rescind until midnight of the 3rd business day following consummation, receipt of the Notice of Right to Cancel, or delivery of all material disclosures, whichever occurs last. "Material disclosures" means the disclosure of the APR, the finance charge, the amount financed, the total of payments, the payment schedule, and the disclosures and limitations in sections 1026.32(c) and (d) and 1026.43(g) (if applicable). (12 CFR 1026.23)
Federal - Right of Rescission Variance Failure (TILA)
Right of Rescission Variance Failure (TILA) Final Disclosure after Consummation Date (Loan Disbursement Date Missing)(1000866)
You did not provide a Loan Disbursement Date and the Last Closing Disclosure (_) was sent after Consummation, so the system assumes the CD with the "material disclosures" was provided before or on the (_) Consummation Date. The system cannot run any rescission tests without a Loan Disbursement Date. A "consumer" may exercise the right to rescind until midnight of the 3rd business day following consummation, receipt of the Notice of Right to Cancel, or delivery of all material disclosures, whichever occurs last. "Material disclosures" means the disclosure of the APR, the finance charge, the amount financed, the total of payments, the payment schedule, and the disclosures and limitations in sections 1026.32(c) and (d) and 1026.43(g) (if applicable). (12 CFR 1026.23)
Federal - Right of Rescission (Loan Disbursement Violation) (TILA)
Right of Rescission (Loan Disbursement Violation)(TIL) Final Disclosure after Consummation Date (Loan Disbursement Date Missing)(1000867)
You did not provide a Loan Disbursement Date and the Last Closing Disclosure (_) was sent after Consummation, so the system assumes the CD with the "material disclosures" was provided before or on the (_) Consummation Date. The system cannot run any rescission tests without a Loan Disbursement Date. A "consumer" may exercise the right to rescind until midnight of the 3rd business day following consummation, receipt of the Notice of Right to Cancel, or delivery of all material disclosures, whichever occurs last. "Material disclosures" means the disclosure of the APR, the finance charge, the amount financed, the total of payments, the payment schedule, and the disclosures and limitations in sections 1026.32(c) and (d) and 1026.43(g) (if applicable). (12 CFR 1026.23)
Federal - Right of Rescission Disclosure Variance Warning (TILA)
Right of Rescission Disclosure Variance Warning (TILA) Last TIL Disclosure after Consummation Date (Loan Disbursement Date Missing)(14050)
You did not provide a Loan Disbursement Date and the Last Closing Disclosure (_) was sent after Consummation, so the system assumes the CD with the "material disclosures" was provided before or on the (_) Consummation Date. The system cannot run any rescission tests without a Loan Disbursement Date. A "consumer" may exercise the right to rescind until midnight of the 3rd business day following consummation, receipt of the Notice of Right to Cancel, or delivery of all material disclosures, whichever occurs last. "Material disclosures" means the disclosure of the APR, the finance charge, the amount financed, the total of payments, the payment schedule, and the disclosures and limitations in sections 1026.32(c) and (d) and 1026.43(g) (if applicable). (12 CFR 1026.23)
Federal - Right of Rescission Disclosure Variance Failure (TILA)
Right of Rescission Disclosure Variance Failure (TILA) Last TIL Disclosure After Consummation (Loan Disbursement Date Missing)(14060)
You did not provide a Loan Disbursement Date and the Last Closing Disclosure (_) was sent after Consummation, so the system assumes the CD with the "material disclosures" was provided before or on the (_) Consummation Date. The system cannot run any rescission tests without a Loan Disbursement Date. A "consumer" may exercise the right to rescind until midnight of the 3rd business day following consummation, receipt of the Notice of Right to Cancel, or delivery of all material disclosures, whichever occurs last. "Material disclosures" means the disclosure of the APR, the finance charge, the amount financed, the total of payments, the payment schedule, and the disclosures and limitations in sections 1026.32(c) and (d) and 1026.43(g) (if applicable). (12 CFR 1026.23)
Federal - Right of Rescission (Loan Disbursement) (TILA)
Right of Rescission (Loan Disbursement)(TILA) Last TIL Disclosure After Consummation (Loan Disbursement Date Missing)(14070)
You did not provide a Loan Disbursement Date and the Last Closing Disclosure (_) was sent after Consummation, so the system assumes the CD with the "material disclosures" was provided before or on the (_) Consummation Date. The system cannot run any rescission tests without a Loan Disbursement Date. A "consumer" may exercise the right to rescind until midnight of the 3rd business day following consummation, receipt of the Notice of Right to Cancel, or delivery of all material disclosures, whichever occurs last. "Material disclosures" means the disclosure of the APR, the finance charge, the amount financed, the total of payments, the payment schedule, and the disclosures and limitations in sections 1026.32(c) and (d) and 1026.43(g) (if applicable). (12 CFR 1026.23)
CER-24852
Section 35 Exemptions Now Exclude Loans with a Term of 12 Months or Less
Loan Term <= 12 Months(1001492)
This loan has a term of (_) months. The System did not test for Federal Higher Priced Mortgage Loan escrow requirements because a loan with a maturity of 12 months or less is exempt. (12 CFR 1026.35(b)(2)(i)(C))
Property is Located in Rural or Underserved County(1000156)
The state and county FIPS code of (_) for the property located in (_) which secures this Federal HPML matches the state and county FIPS code on the list of rural or underserved counties published by the CFPB. 12 CFR 1026.35 provides that a small creditor operating predominantly in rural or underserved areas is not required to establish an escrow account for taxes and insurance for a Federal HPML if the creditor: (1) during the preceding calendar year, extended more than 50% of its total covered transactions on properties located in designated rural or underserved counties; (2) together with its affiliates, originated no more than 500 covered transactions during the preceding calendar year; (3) had total assets of less than $2 billion, as of the end of the preceding calendar year; and (4) together with its affiliates do not maintain certain types of escrow accounts. (12 CFR 1026.35(b)(2)(iii),(iv))
The following Rule Headers no longer receive a FAIL, ALERT, or WARNING status message for Section 35 for a loan with a term of 12 months or less:
- RH 1000137 Federal - Escrow Account Required (First Lien HPML)(06/2013)
- RH 1000156 Federal - HPML Rural or Underserved County Alert (First Lien)(06/2013)
CER-24933
State Rules
IOWA: Iowa Money and Interest Provisions FAIL Status Messages Now Include Subsection “(a)” to Section 535.8(a) Messages
You can now distinguish between Subsection 535.8(a) and 535.8(b) more effectively in
CER-24865
IOWA: Certain Fees Excluded Under Rule Header 1001480 Iowa - Fees Not Allowed (535.8(4)(b)) When Charged to Any Party and Paid to Any Party
This update affects all primary and second/vacation dwellings up to two units secured by Iowa real property.
The following new Rule Header is affected:
- Iowa - Fees Not Allowed (535.8(4)(b))(1001480)
This applies to all clients utilizing State Rules review.
We have updated the system default behavior where the system provided a FAIL status message under the Iowa Subsection for certain fees charged to any party and paid to any party by removing the following fees from the prohibited fees list:
| Fee Name |
|---|
| 203(k) Permits |
| 203(k) Title Update Fee |
| Doc Tax Stamps for Note |
| Doc Tax Stamps/Transfer Taxes - City/County |
| Doc Tax Stamps/Transfer Taxes - State |
| Filing Fees |
| Inspection Fees Collected After Closing |
| Insurance Impound - Flood |
| Insurance Premium - Flood |
| Insurance Premium - Windstorm |
| Intangible Tax |
| Municipal Lien Certificate Recording Fee |
| Water Allotment Payment |
As a result, system default functionality for Rule Header 1001480 Iowa - Fees Not Allowed (535.8(4)(b)) will provide a FAIL status message if any of the following fees are charged:
| Fee Name |
|---|
| Administration Fee |
| AK Program Administration Fee |
| AL Interest Surcharge |
| Application Deposit |
| Application Fee |
| Appraisal Desk Review Fee |
| Appraisal Field Review Fee |
| Appraisal Review Fee |
| Assignment Fee |
| Assumption Fee |
| Attendance/Pickup Fee |
| Bankruptcy Monitoring Fee |
| Bond Fee |
| Bond Review Fee |
| CLO Access Fee |
| Closing Protection Letter |
| Compliance Testing Fee |
| Courier Fee |
| Credit Disability Insurance-Impound |
| Credit Life Insurance-Impound |
| Credit Unemployment Insurance-Impound |
| Credit Disability Premium |
| Credit Life Premium |
| Credit Unemployment Premium |
| Document Assembly Fee |
| Document Preparation Fee |
| Document Redraw Fee |
| Electronic Document Delivery Fee |
| Escrow Account Servicing Fee |
| Escrow Waiver Fee |
| FL Assessment Recoupment Surcharge |
| Funding Fee |
| GA Residential Mortgage Act Per Loan Fee |
| Handling Fees Collected After Closing |
| HOA Certification Handling Fee |
| Home Warranty Premium |
| IN Title Insurance Enforcement Fund Fee |
| Inspection and Handling Fees Collected After Closing |
| Interest Rate Buy Down Fee |
| Lender's Title Policy |
| Loan Tie-in Fee |
| Loan Warehousing Fee |
| MERS® Registration Fee |
| Modification/Amendment Fee |
| Mortgage Insurance Application Fee |
| Municipal Lien Fee |
| Notary Fee |
| Office Expenses |
| Other Fees Collected After Closing |
| Other Impound |
| Owner's Title Policy |
| Payoff Demand Fee |
| Program Participation Fee |
| Reconveyance Fee |
| Recording Service Fee |
| RESPA - Title Services and Lender's Title Insurance |
| Rush Fee |
| Servicing Release Premium |
| Signing Agent Fee |
| Subordination Fee |
| Subordination Preparation Fee |
| Tax Related Service Fee |
| Tax Status Research Fee |
| Title Endorsement Fee |
| Title Examination |
| Title Insurance |
| Title Insurance Binder |
| Title Search |
| TN Service Charge |
| Underwriting Fee |
| Unknown Fees - Finance Charge |
| Unknown Fees - Non-Finance Charge |
| Wire Transfer Fee |
| Yield Spread Premium/Rebate |
CER-24856
MAINE: CMR Index Lookup WARNING Status Message Updated for Rule Header 1001486 Maine - High Cost CMR Retrieval Date Comparison
CER-24848
