National Association of Independent Housing Professionals
Welcome to the internet home of the National Association of Independent Housing Professionals, NAIHP. Please note, this site is still in the developmental stage and will continually be updated.
Comprised of all housing industry professionals, NAIHP is strictly a legislative and regulatory organization, leaving education and other such issues to trade associations with individual interests. Low membership dues ($50 a year per person), will enable NAIHP to grow into one of the largest grassroots organizations, without creating a financial burden on its membership.
As most legislative and regulatory actions affect the entire housing industry, NAIHP was created to advocate on behalf of all small business housing professionals.
NAIHP Promotes New Appraisal Rules on Capitol Hill
Consumer Groups Slam Brokers,
Consumer Financial Protection Bureau
Finalizes LO Comp Rule
NAIHP Comment Letter
NAIHP Comment letter on Points and Fees calculations
"Qualified Mortgage" Rule
Ability to Repay Rule
A Summary of the final Ability-to-Repay rule is at:
A fact sheet further explaining the new rule is at:
The rule and proposed amendments:
Committee on Oversight and Government Reform
Report on the CFPB
Read and Sign the Petition concerning the Interim Final Rule on Appraiser Independence
Please forward the petition to your database, including those consumers harmed by this rule. Be sure to forward to mortgage brokers, appraisers, mortgage bankers, real estate agents, etc.
NAIHP and State Mortgage Professionals Comment on CFPB’s Proposed Rule… "
NAIHP challenges CFPB on new Consumer Advisory Board and
"Level Playing Field."
CFPB Issues Proposed Rules on Originator Compensation & Qualifications
Proposed Rules on MLO Compensation and more
Agencies Release Proposed Rule On Appraisals for High Risk Mortgages.
Extended Anti-Money Laundering Regulations Begin Monday, August 13th
NAIHP Anti-Money Laundering Compliance Package Available:
NAIHP Members: $299.00
CFPB issues 2 Proposed Rules
Proposed Rule #1
New Loan Estimates (GFE/TIL) and New Closing Disclosure
Simpler than the old forms. Consumers can understand and compare different mortgages more effectively, and examine their estimated and final terms and costs more easily, helping them make the right decisions for themselves and their families.
Highlight information consumers need. Interest rates, monthly payments, the loan amount, and closing costs are all right there on the first page of the CFPB proposed form. Also, the first page explains how the interest rates, payments, and loan amount might change over the life of the loan, including the highest they can go. In addition, the forms offer more information about taxes, insurance, and other property costs so consumers can better understand the total cost.
Easier to look out for risks. The forms provide clear warnings about features some consumers may want to avoid, such as prepayment penalties and an increase in the loan balance (negative amortization). The proposed rule also contains provisions to make estimates more reliable. And because the proposed rule requires lenders to keep electronic copies of the forms they give to consumers, industry and regulators will be able to address compliance questions more easily.
More time to consider choices. Lenders must give the Loan Estimate to consumers within three business days of applying for a loan and consumers must receive the Closing Disclosure at least three business days before closing on a loan. This will allow consumers to decide whether to go ahead with the loan and whether they are getting what they expected.
Limits on closing cost increases. The proposed rule would restrict circumstances in which consumers can be required to pay more for settlement services than the amount stated on their Loan Estimate.
Proposed Rule #2
High Cost Mortgage Protections
The proposed rule would implement Congress’s expansion of the Home Ownership and Equity Protection Act (HOEPA) with respect to mortgages with high interest rates, fees, or prepayment penalties. The CFPB’s proposal would:
Ban potentially risky features. For mortgages that qualify as high-cost based on their interest rates, points and fees, or prepayment penalties, the proposed rule would generally ban balloon payments (a large, lump sum payment usually due at the end of the loan), and would completely ban prepayment penalties.
Ban and limit certain fees. The CFPB’s proposed rule would ban fees for modifying loans, cap late fees, and restrict the charging of fees when consumers ask for a payoff statement (a document that tells borrowers how much they need to pay off the loan).
Require housing counseling for high-cost mortgages. The proposed rule would require consumers to receive housing counseling before taking out a high-cost mortgage. In addition, the CFPB’s proposal would implement TILA counseling requirements for first-time borrowers taking out certain mortgage loans that permit negative amortization. The proposal would also implement an amendment to RESPA to generally require that a list of housing counselors or counseling organizations be provided to all mortgage applicants.
After careful review of these proposals,NAIHP will post our comments.
Comment period (60 days) ends September 7, 2012
NAIHP submits coalition comment letter to CFPB on proposed changes to Loan Originator Compensation
NAIHP offers CFPB-
Alternative to LO Comp Rule & Flat Fee
“As an alternative to the proposed changes in mortgage loan origination standards, the CFPB should exercise its exemption authority under Dodd-Frank, by specifically exempting all prime/traditional and government loans from the MLO Compensation regulations, while retaining the proposed restrictions for high cost and subprime mortgages. It would eliminate any incentive for placing a prime qualified borrower in a high cost mortgage for the purpose of greater financial gain and would be a far less burdensome solution. Moreover, it would establish a firewall to protect consumers from steering, while restoring consumer choice to the prime market. We urge the CFPB to adopt this alternative.”
Statement by Elizabeth Warren
"I believe that clearer, simpler regulation—regulation that is designed to work for small businesses and consumers—can help make markets work better. The financial crisis showed us what happens when regulations aren’t enforced and giant Wall Street businesses have too little oversight. Deregulation certainly didn’t help the small banks and credit unions that got swept up in that mess. But we also can’t keep layering on one regulation after another, adding more and more complexity, without assessing the effects on families and small businesses.
We need a new approach that includes a serious assessment of the compliance cost of current regulations and whether adequate protection for consumers can be accomplished using cheaper, simpler approaches, or, in specific cases, if the regulations are so heavily layered on top of each other that some can be cut altogether." Elizabeth Warren
NAIHP to CFPB
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