Navigating Mortgage Compliance: Understanding Recent UDAP Changes

Regulatory changes have been coming fast and furious in the credit union mortgage industry, leaving many wondering what’s still required and what’s been relaxed. In this eye-opening episode, Amanda Phillips, General Counsel and EVP of Compliance with ACES Quality Management, guides us through the regulatory maze with remarkable clarity.

Amanda brings her extensive compliance knowledge to bear on one of today’s hottest topics: the withdrawal of policy statements regarding abusive acts and practices (UDAP). We explore what this means practically for credit unions, particularly regarding post-closing and servicing operations. With her unique ability to make complex compliance issues accessible, Amanda helps us understand that while certain guidance has been withdrawn, core obligations remain.

The conversation takes a deep dive into PMI termination requirements, distinguishing between automatic termination (based on original loan values) and borrower-requested termination (potentially based on current valuations). We examine the potential pitfalls of online property value estimates and how they relate to PMI obligations. This section alone could save your credit union from serious compliance headaches!

We also explore how the withdrawal of guidance on “unauthorized and unreasonable fees” impacts what credit unions can charge. Amanda emphasizes that transparency remains the key, even as regulatory frameworks shift. Her insights on loss mitigation rule changes provide critical context for servicing teams navigating post-pandemic realities.

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