By Brian Johnson

This is Part 2 of the ongoing “Are we completing our GFEs correctly?” series.

“Are we completing our Good Faith Estimates (GFEs) correctly?” This is how I started out my blog back on November 17th and if you read it, you discovered that most credit unions are not completing the GFEs correctly. As you can imagine, there are more common mistakes being made on the GFE than just those I described in my previous blog.

The Consumer Financial Protection Bureau unveiled a prototype credit card agreement yesterday (12/7) as part of the bureau’s Know Before You Owe campaign, which had previously released simplified model disclosures for mortgages and student loans.

Obviously a credit card agreement is fundamentally different than a model disclosure, so it will be interesting to see how this prototype evolves once feedback and testing is completed.

For more information about the new prototype, visit the CFPB website or this AP news story.

Are we completing our Good Faith Estimates (GFEs) correctly?  This is a question that I frequently receive from credit unions even though we are almost two years removed from the required implementation of the new GFE.  And as it turns out, many credit unions are still not completing them correctly. So, with the anniversary approaching, I thought now would be a good time to review some common mistakes made on a very common form. As the title of today’s post indicates, this is the beginning of a series of posts describing common mistakes and instructions on how to complete the GFE correctly.

Today’s common mistake: “Your Adjusted Origination Charges”

And you thought worrying about the SAFE Act was over!  Just in time for Halloween, it is time to start thinking about staying SAFE by renewing your registration on the NMLS Federal Registry.  In case you forgot, the SAFE Act requires Mortgage Loan Originators (MLOs) and institution account holders (your credit union) to renew their registrations annually between November 1st and December 31st.

Everyone knows that re-disclosing documents are a pain; however, most credit unions do a very good job of making sure that the documents are re-disclosed when required.  Many credit unions over re-disclose certain documents even when they are not required to do so.  One re-disclosure issue which I am seeing more frequently is the re-disclosure of the APR for mortgage transactions.