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Read articles below for analysis and discussion of recent trends by BM&G’s industry experts.

FHA Qualified Mortgage 2015 Points and Fees Adjustments

In the February 17, 2015 issue of the Federal Register (80 FR 8243, click here) the Department of Housing and Urban Development (HUD) announced the 2015 points and fees threshold for FHA qualified mortgages by adopting the Consumer Financial Protection Bureau’s August 14, 2014 final rule amending the qualified mortgage points and fees limit for 2015 (see our August 19, 2014 memorandum, click here).

Annual FHA MIP Reduction Memo (ML 2015-01)

Effective for case numbers assigned on or after January 26, 2015, FHA Mortgage Letter 2015-01 (ML 2015-01) reduces annual MIP rates for FHA Title II forward mortgages and provides FHA lenders the opportunity for cancellation of existing case numbers in order to utilize the MIP rates contained in ML 2015-01.

FHA Adjustable Rate Mortgage Interest Rate Adjustment and Notification Regulations under the FHA Single Family Mortgage Insurance Program are Revised

In the August 26, 2014, Federal Register (79 FR 50838), the Federal Housing Administration (FHA) published a final rule (click here) that revises two FHA single family adjustable rate mortgage (ARM) regulations. The final rule revises §203.49(d)(2) to require that an interest rate adjustment resulting in a corresponding change to the mortgagor’s monthly payment for a FHA-insured ARM have a 45-day look-back period.

FHA Final Rule Prohibits Post-Payment Interest Charges for Prepayment of FHA Mortgages under the FHA Single Family Mortgage Insurance Program

In the August 26, 2014, Federal Register (79 FR 50835), the Federal Housing Administration (FHA) published a final rule (click here) that effective for FHA-insured mortgages closing on or after January 21, 2015, revises FHA’s regulations to prohibit an FHA approved mortgagee from charging the mortgagor interest through the end of the month in which the mortgage is being prepaid, allowing them instead to charge interest only through the date the mortgage is prepaid, and prohibits the charging of interest beyond that date.

FHA Proposes to Prohibit Post-Payment Interest Charges for Prepayment of Loans under the FHA Single Family Mortgage Insurance Program

In the March 13, 2014, Federal Register (79 FR 14200), the Federal Housing Administration (FHA) published a proposed rule (click here) to revise FHA’s regulations to prohibit an FHA approved mortgagee from charging the mortgagor interest through the end of the month in which the mortgage is being prepaid, allowing them instead to charge interest only through the date the mortgage is prepaid. This proposed change to FHA prepayment regulations is in response to the Ability-to-Repay and Qualified Mortgage regulations (ATR/QM Rule) issued by the Consumer Financial Protection Bureau (CFPB), which became effective January 10, 2014. The ATR/QM Rule defines “prepayment penalty” in closed-end transactions as “a charge imposed for paying all or part of the transaction’s principal before the date on which the principal is due.” The ATR/QM Rule specifically excludes a post-payment interest charge currently allowed by FHA regulations as a prepayment penalty for FHA loans consummated before January 21, 2015. However, for FHA loans closed on or after January 21, 2015, a post-payment interest charge will be considered a prepayment penalty by the ATR/QM Rule, thus making it necessary for FHA to amend its regulations.

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