Rules in April 2025 Release

Enterprise

ECS has been updated to provide warning and info status messages for VA loan submissions under RH 1001280 Federal - VA Loan Origination and Other Restricted Fees - State Fee Deviation for Pennsylvania and New York.

Federal - VA Loan Origination and Other Restricted Fees - State Fee Deviation

VA Loan Including Fee Deviation Not to Exceed Limit (Verification Fee)(1001280)

This loan contains a Verification Fee of ($_) paid by a borrower. Under VA Guidelines for (_), a veteran can exclude a charge for a Verification Fee up to $25 from the "unallowable fees". The system assumes you are asserting that these requirements have been satisfied by submitting this fee. (38 CFR 36.4313; VA Circular 26-17-11; VA State Fees and Charges Deviations Change Sheet)

VA Loan Including Fee Deviation Not to Exceed Limit (Closing Protection Letter Fee) (DE or PA)(1001280)

This loan contains a Closing Protection Letter Fee of ($_) paid by a borrower. Under VA Guidelines for (_), a veteran can exclude a charge for a Closing Protection Letter Fee up to $125 from the "unallowable fees". The system assumes you are asserting that these requirements have been satisfied by submitting this fee. (38 CFR 36.4313; VA Circular 26-17-11; VA State Fees and Charges Deviations Change Sheet)

VA Loan Including Fee Deviation Not to Exceed Limit (Title Endorsement Fee) (NY)(1001280)

This loan contains a Title Endorsement Fee of ($_) paid by a borrower. Under VA Guidelines for (_), a veteran can exclude a charge for a Title Endorsement Fee up to $50 from the "unallowable fees". The system assumes you are asserting that these requirements have been satisfied by submitting this fee. (38 CFR 36.4313; VA Circular 26-17-11; VA State Fees and Charges Deviations Change Sheet)

Title Endorsement Fee Excluded from VA 1% (State Fee Deviation Sheet)(NY)(1001280)

This loan contains a Title Endorsement Fee of ($_) paid by a borrower. Under VA Guidelines for (_), a veteran can exclude a charge for a Title Endorsement Fee from the "unallowable fees". Veterans may not be charged more than the invoiced amount or for services already paid for by another party. Lenders are responsible for ensuring the amount charged is compliant with any state maximums. (38 CFR 36.4313; VA Circular 26-24-19; VA State Fees and Charges Deviations Change Sheet)

CER-24981

Federal

ECS has been updated to include a new INFO status message, and updated its default system behavior to no longer return FAIL, ALERT, and WARNING status messages, for users who submit a closed end loan with a loan term of 12 months or less under the ATR/QM or QM Enterprise Review. The new INFO status message provides additional information about loan eligibility.

Federal - Ability to Repay Exemption (01/14)

ATR Exempt Transaction(1000243)

This loan is an ATR Exempt Mortgage. You submitted an ATR Exempt Transaction Type of (_), which is a type of transaction listed as exempt from the ability to repay requirements of Section 43. (12 CFR 1026.43(a)(2); 1026.43(3)(i)-(iv)&(vi))

Loan Term <= 12 Months (Exempt)(1000243)

This is an ATR Exempt Loan. It is a temporary or "bridge" loan with a term of 12 months or less. It is not a "covered transaction" and is not subject to the Ability-to-Repay Requirements of Regulation Z, 12 CFR 1026.43(c)-(f). (12 CFR 1026.43(a)(3)(ii))

Loan Term <= 12 Months Exemption(1000243)

This is an ATR Exempt Loan. The system did not perform a Federal QM analysis because this loan file is a temporary loan with a term of 12 months or less. It is not a "covered transaction" and is not subject to the Ability-to-Repay Requirements of Regulation Z, 12 CFR 1026.43(c)-(f). (12 CFR 1026.43(a)(3)(ii))

CER-24941

State Rules

ECS has been updated to incorporate changes introduced by the Maine Bureau of Consumer Credit Protection's Interpretive Letter dated March 18, 2025, regarding the definition of "conventional mortgage rate" in the Maine Truth in Lending Act. This update reflects the revised provisions of the Maine Consumer Credit Code (Title 9-A M.R.S.) and the use of the 30-year fixed-rate mortgage ("30-Yr FRM") as published in the weekly Primary Mortgage Market Survey ("PMMS") as a substitute for the discontinued Fed CMR.

As a result, ECS has sunsetted the existing WARNING status message under RH 1001486 Maine - High Cost CMR Retrieval Date Comparison.

CER-25001

ECS has been updated to reflect the new address of the Massachusetts Division of Banks, which is now located at One Federal Street, Suite 710, Boston, MA 02110-2012.

To ensure accurate reporting, users who have previously submitted loans with the old address (One South Station, 3rd Floor, Boston, MA 02110) are advised to re-run their Mavent Reports to reflect the updated address.

CER-24945

The Oklahoma Department of Consumer Credit released the changes to many dollar amounts in the Oklahoma Uniform Consumer Credit Code. Certain dollar amounts in the Uniform Consumer Credit Code are subject to change on July first of every year based on changes in the Consumer Price Index.

For all loans originated on or after July 1, 2025, ECS will return a FAIL status message if a loan meets the following criteria:

  • A late fee of no less than $5, or more than the greater of 5% or $33.00 is included; or
  • The loan amount is $6,600 or less.
Effective Dates July 1, 2024 - June 30, 2025 July 1, 2025 - June 30, 2026
Oklahoma - Maximum Late Fee $32.00 $33.00
Oklahoma - Minimum Loan Value $6,400 $6,600

The following rule headers are affected by this change:

Oklahoma - Maximum Late Fee

Max Late Fee(54310)

Under the Oklahoma UCCC, the late fee must be greater than $5 and cannot exceed the greater of 5% of the overdue payment or ($_). (Ok. St. 14A 3-203(5))

Oklahoma - Minimum Loan Value

Minimum Loan Amount(29330)

The Oklahoma UCCC does not allow a loan of ($_) or less to be secured by a mortgage. (Ok. St. 14A 3-510)

To understand the specific dollar amount changes and threshold requirements, please refer to the Uniform Consumer Credit Code, specifically Section 14A:1-106(1), (2), (3), and (4), which outlines the Consumer Price Index (CPI-W) adjustments for the State of Oklahoma.

View the Uniform Consumer Credit Code

CER-24997

ECS has been updated to reflect changes to the max rate limit for Tennessee loans made under the Industrial Loan & Thrift license, as per Tennessee SB 694. The max rate limit has increased from 30% to 36% for loans consummated on or after July 1, 2025.

The following Rule Header is affected by this change:

Tennessee - Max Rate (ILTCA)

Rate Must Be <= 36% on Loans > $100 (07/25)(53070)

The rate (_%) does not exceed the Tennessee Industrial Loan and Thrift Companies Act limit of 36% for financed amounts greater than $100. (Tenn. Code Ann. 45-5-301)

Rate Must Be <= 36% on Loans > $100 (07/25)(53070)

The rate (_%) exceeds the Tennessee Industrial Loan and Thrift Companies Act limit of 36% for financed amounts greater than $100. (Tenn. Code Ann. 45-5-301)

For all loans originated on or after July 1, 2025 ECS will return a FAIL status message for Tennessee loans submitted using the Industrial Loan and Thrift Companies Act (ILTCA) license, if the rate is greater than the following:

Loan Amount Old Rate (effective through 06/30/25) New Rate (effective 07/01/25)
> $5,000 24% 36%
$2,500 - $5,000 30% 36%
$100 - $2,500 36% 36%
$0 - $99 7.5% (nominal) / 18% (effective) 18%

To learn more about the changes to the Tennessee Code Annotated, Title 45, Chapter 5, as outlined in Senate Bill 694, please refer to the official legislation document.

View Tenn. Code Ann. 45-5-301

CER-25023

Current Section

Current Section

Rules in April 2025 Release