Federal Housing Administration (FHA): Handling Prepayments: Eliminating Post-Payment Interest Charges, 50835-50838 [2014-20214]
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50835
Rules and Regulations
Federal Register
Vol. 79, No. 165
Tuesday, August 26, 2014
This section of the FEDERAL REGISTER
contains regulatory documents having general
applicability and legal effect, most of which
are keyed to and codified in the Code of
Federal Regulations, which is published under
50 titles pursuant to 44 U.S.C. 1510.
The Code of Federal Regulations is sold by
the Superintendent of Documents. Prices of
new books are listed in the first FEDERAL
REGISTER issue of each week.
DEPARTMENT OF HOUSING AND
URBAN DEVELOPMENT
24 CFR Part 203
[Docket No. FR–5360–F–02]
RIN 2502–AJ17
Federal Housing Administration (FHA):
Handling Prepayments: Eliminating
Post-Payment Interest Charges
Office of the Assistant
Secretary for Housing-Federal Housing
Commissioner, HUD.
ACTION: Final rule.
AGENCY:
This rule revises FHA’s
regulations that allow an FHA-approved
mortgagee to charge the mortgagor
interest through the end of the month in
which the mortgage is being paid. The
final rule allows mortgagees to charge
interest only through the date the
mortgage is paid, and prohibits the
charging of interest beyond that date.
DATES: Effective Date: January 21, 2015.
FOR FURTHER INFORMATION CONTACT:
Ivery Himes, Director, Office of Single
Family Asset Management, Office of
Housing, Department of Housing and
Urban Development, 451 7th Street SW.,
Room 9172, Washington, DC, 20410;
telephone number 202–708–1672 (this
is not a toll-free number). Persons with
hearing or speech impairments may
access this number through TTY by
calling the toll-free Federal Relay
Service at 800–877–8339.
SUPPLEMENTARY INFORMATION:
SUMMARY:
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I. Background—the March 13, 2014
Proposed Rule
On March 13, 2014, HUD published a
proposed rule in the Federal Register, at
79 FR 14200, to eliminate post-payment
interest charges to borrowers resulting
from FHA’s monthly interest accrual
amortization method for calculating
interest. This change was responsive to
the final rule of the Consumer Financial
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Protection Bureau (CFPB) entitled
‘‘Ability-to-Repay and Qualified
Mortgage Standards under the Truth in
Lending Act (Regulation Z)’’ (CFPB final
rule) 1, which broadly defines
‘‘prepayment penalty’’ in closed-end
transactions as the ‘‘charge imposed for
paying all or part of the transaction’s
principal before the date on which the
principal is due,’’ thus including
charges resulting from FHA’s monthly
interest accrual amortization method
(see 12 CFR 1026.32(b)(6)).2
HUD’s March 13, 2014, rule proposed
to revise the regulations in 24 CFR
203.558 to provide that, with respect to
FHA-insured mortgages closed on or
after the effective date of the proposed
regulatory amendments, and
notwithstanding the terms of the
mortgage, the mortgagee shall accept a
prepayment at any time and in any
amount and shall not charge a postpayment charge. The March 13, 2014,
rule proposed to require that monthly
interest on the debt be calculated on the
actual unpaid principal balance of the
loan as of the date the prepayment is
1 This rule was first issued on the CFPB’s Web
page at https://files.consumerfinance.gov/f/201301_
cfpb_final-rule_ability-to-repay.pdf and
subsequently published in the Federal Register on
January 30, 2013, at 78 FR 6408.
2 Prior to enactment of the Dodd-Frank Wall
Street Reform and Consumer Protection Act (Pub.
L. 111–203, approved July 21, 2010) (Dodd-Frank
Act), the Federal Reserve Board (Board) had
responsibility for lenders’ compliance with the
Truth in Lending Act (TILA). (This responsibility
was transferred to the CFPB in July 2011.) In a
September 2009 interpretive letter to Secretary
Donovan, Board staff advised that they had not
addressed whether monthly interest accrual
amortization is a prepayment penalty and,
therefore, would not prohibit such practice without
further review. (See https://www.aba.com/
Compliance/Documents/da4a00df3ffb4650
b7c9154adbc1418aFedLtrtoHUD2009.pdf.) In a
proposed rule published on September 24, 2010, at
75 FR 59539, the Board proposed to amend
Regulation Z, which implements TILA and the
Board’s accompanying staff commentary. In this
proposed rule, the Board stated that based on
further review and analysis the monthly interest
accrual amortization method should be treated as a
prepayment penalty for TILA purposes. (See 75 FR
58586.) The CFPB’s final rule on ability-to-repay
continued the analysis that the Board provided in
its September 24, 2010, proposed rule and
categorized FHA’s monthly interest accrual
amortization method as a prepayment penalty, but
not for FHA loans consummated before January 21,
2015. (See 78 FR 6445.) The CFPB offers examples
of the monthly interest accrual amortization method
at page 78 FR 6600. In its discussion at this page,
the CFPB recognized that FHA would need
rulemaking to change this practice and the amount
of time needed to complete the rulemaking.
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received and not as of the next
installment due date.
While the CFPB final rule permits
limited prepayment penalties for
‘‘qualified mortgages’’ (as that term is
defined in the CFPB final rule) during
the first 36 months following
consummation of the mortgage (see 12
CFR 1026.43(g)), such penalties are not
permitted for higher-priced mortgage
loans or for loans that have an
adjustable interest rate.3 As a result of
these restrictions, and in order to
maximize consistency among FHAinsured single family mortgage products
and provide the same protections for all
borrowers, HUD’s March 13, 2014, rule
proposed to prohibit prepayment
penalties in all FHA-insured single
family mortgages.
In addition to amending § 203.558,
the March 13, 2014, proposed rule
offered two technical conforming
changes to the regulations in 24 CFR
part 203. See the March, 13, 2014,
proposed rule for a greater discussion
on the technical changes.
II. This Final Rule
This final rule follows publication of
the March 13, 2014, proposed rule and
adopts that proposed rule without
change. The public comment period for
the proposed rule closed on May 12,
2014, and HUD received four public
comments. Section III of this preamble
discusses the comments received on the
proposed rule.
III. Discussion of Public Comments
Received on the March 13, 2014,
Proposed Rule
The public commenters included a
mortgage company and trade
associations. Commenters were over-all
supportive of HUD’s proposal to
prohibit the charging of post-payment
interest on FHA loans.
Comment: Maintain proposed
implementation language and publish a
final rule as soon as practicable. A
commenter requested that HUD
maintain the implementation language,
‘‘closed on or after [the effective date of
the rule]’’, as opposed to using case
number assignment or some other date.
The commenter explained that the
technological and procedural changes
needed to implement this rule will
3 See HUD’s March 13, 2014, proposed rule for
additional information related to this prohibition;
see also 12 CFR 1026.43(g)(1)(i)(A).
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require a long lead time and any change
to the implementation language may
delay lenders’ abilities to fully comply
with the rule. The commenter also
requested that the final rule be
published as soon as practicable to
provide the industry with clarity and
certainty.
HUD Response: HUD appreciates the
industry’s support of this rule and
desire for a quick implementation, and
is not making any changes to the
implementation language.
Comment: Concern that lenders will
recoup the costs of not collecting postpayment interest by charging higher
interest rates or servicing fee differential
is overstated. In response to HUD’s
statement in the preamble to the
proposed rule that HUD expects lenders
will simply look elsewhere to recoup
funds lost by not being able to charge
interest beyond the mortgage payment
date, a commenter explained that
lenders continue to offer Veterans
Administration (VA) and Rural Housing
Service (RHS) loans, which are
securitized by Ginnie Mae and, these
loans do not have prepayment penalties,
but offer interest rates similar to current
FHA rates. The commenter also stated
that FHA loans are attractive to
investors, regardless of the excess
interest payments, because they carry
the guarantee of the federal government.
HUD Response: The commenter raises
a good point, which HUD appreciates
and hopes reflects how lenders will
handle FHA-insured loans that now
prohibit post-payment interest, and that
is by continuing to offer the same
interest rates that they offer now.
Comment: Publish additional
information in the final rule or in a
concurrent Mortgagee Letter. A
commenter asked HUD to publish
revised maximum mortgage
calculations, for FHA refinance
transactions, to include the actual
amount of interest to be paid and
financed. The commenter also asked
that HUD consider a closing date
change, and the impact on the
maximum mortgage calculation, to be
included in the existing policy for
minor adjustments at closing.
HUD Response: HUD appreciates this
concern, but believes the current policy
provides adequate flexibility in
calculating the maximum mortgage
eligible for FHA refinance transactions.
FHA policy permits interest due on the
previous mortgage to be financed into
the new FHA mortgage. The amount of
interest that is permitted to be financed
varies based upon the refinance
program. However, each program that
limits the financing of interest allows
for a flexibility of $500 in determining
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the maximum mortgage amount. HUD
expects that this flexibility provides
sufficient leeway to account for changes
in the interest due on the previous
mortgage as a result of changes in the
closing date.
Comment: Passing costs on to
borrowers is not a consumer protection.
One commenter raised a concern that if
servicers of FHA loans continue to be
obligated to pay investors charges that
the servicers may no longer collect from
consumers, as required by Ginnie Mae,
originating lenders and servicers will
need to price that charge into the cost
of the loan, raising costs for FHA
borrowers, which is not a consumer
protection. The commenter requested
that HUD, FHA, Ginnie Mae, and the
CFPB coordinate actions so that the
intended consumer protections can be
implemented.
Another commenter explained that
under current regulations, borrowers
could choose to avoid paying postpayment interest by paying off the loan
at the end of the month. Under the
proposed rule, however, all borrowers
would have to pay more, including
those borrowers who would have
strategically avoided paying postpayment interest under the current
regulations.
HUD Response: HUD appreciates this
concern, but emphasizes that any cost
passed on to the consumer by the
servicer, as a result of the ability for
security holders to continue to collect
interest through the end of the month,
is expected to be minimal. In addition,
not all consumers will experience
additional costs. For example,
consumers who would have prepaid
their mortgages and would have been
subject to post-payment interest charges
under FHA’s regulations, prior to
amendment by this rule, will no longer
be subject to those charges. These
consumers may end up paying slightly
more in interest each month or a higher
servicing fee differential, but will avoid
a post-payment charge when prepaying
their mortgage later on, off-setting the
cost of slightly increased interest rates
or servicing fee differentials.
In addition, as another commenter
mentioned, lenders continue to offer VA
and RHS loans, which are securitized by
Ginnie Mae and permit security holders
to collect interest through the end of the
month, but do not allow for prepayment
penalties. The interest rates on these VA
and RHS loans are similar to current
FHA rates, illustrating that costs are not
being passed on to borrowers in the
manner of higher interest rates.
Comment: Pressure placed on
mortgage servicers. A commenter
explains that the proposed rule would
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place further pressure on mortgage
servicers, at a time when servicing costs
continue to rise. The commenter
explained that servicers will have
higher direct costs, and that the rule
would impact the value of FHA
mortgage servicing rights.
HUD Response: HUD appreciates this
concern; however, the impact on
servicers is consistent with prevailing
industry practice. As discussed
previously, GSE, VA, and RHS loans do
not require borrowers to pay postpayment interest.
Comment: FHA should work with
Ginnie Mae to transition to a daily
simple interest calculation structure.
This structure would calculate interest
daily based on outstanding principal
balance, rather than as a predetermined
monthly amount, and align the cash
flows from the underlying loans with
the payments made to investors in the
mortgage-backed securities.
HUD Response: At this time, FHA
declines the suggestion to work with
Ginnie Mae to transition to a daily
simple interest calculation structure.
The simple interest calculation structure
poses unnecessary risks to borrowers.
For example, interest accrues daily on
the unpaid principal balance instead of
monthly, so there is no grace period for
payments. In addition, the loan will not
fully amortize over the stated term if the
borrower makes payments later than the
scheduled due date.
IV. Findings and Certifications
Regulatory Review—Executive Orders
12866 and 13563
Under Executive Order 12866
(Regulatory Planning and Review),
agencies must determine whether a
regulatory action is significant and,
therefore, subject to review by the Office
of Management and Budget (OMB) in
accordance with the requirements of the
order. Executive Order 13563
(Improving Regulations and Regulatory
Review) directs executive agencies to
analyze regulations that are ‘‘outmoded,
ineffective, insufficient, or excessively
burdensome, and to modify, streamline,
expand, or repeal them in accordance
with what has been learned.’’ Executive
Order 13563 also directs that, where
relevant, feasible, and consistent with
regulatory objectives, and to the extent
permitted by law, agencies are to
identify and consider regulatory
approaches that reduce burdens and
maintain flexibility and freedom of
choice for the public. At the proposed
rule stage, this document was
determined to be a ‘‘significant
regulatory action’’ as defined in section
3(f) of the Executive order (although not
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Federal Register / Vol. 79, No. 165 / Tuesday, August 26, 2014 / Rules and Regulations
an economically significant regulatory
action, as provided under section 3(f)(1)
of the Executive order). While this rule
remains a significant regulatory action,
HUD is adopting the proposed rule
without change, and therefore further
review of this rule under EO 12866 is
not necessary. Additionally, the
regulatory impact of this rule,
specifically the costs and benefits of this
rule, as presented in the preamble to the
proposed rule at 79 FR 14202 through
14203 remain applicable to this rule.
Regulatory Flexibility Act
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The Regulatory Flexibility Act (RFA)
(5 U.S.C. 601 et seq.) generally requires
an agency to conduct a regulatory
flexibility analysis of any rule subject to
notice and comment rulemaking
requirements, unless the agency certifies
that the rule will not have a significant
economic impact on a substantial
number of small entities. As noted
above in this preamble, even without
rulemaking by HUD, the circumstances
in which a small entity could charge a
prepayment penalty have been
significantly limited by the CFPB final
rule. The CFPB final rule implements
the Dodd-Frank Act provisions that
generally prohibit prepayment penalties
except for certain fixed-rate, qualified
mortgages where the penalties satisfy
certain restrictions and the creditor has
offered the consumer an alternative loan
without such penalties. The CFPB final
rule categorizes the post-payment
interest charge resulting from FHA’s
monthly interest accrual amortization
method as a prepayment penalty.
Therefore, the use of post-payment
interest charges on all FHA loans closed
on or after January 21, 2015, will be
considered prepayment penalties. This
is true, irrespective of any economic
impacts of the rule.
In any event, even if HUD were to
issue a rule allowing prepayment
penalties, the CFPB final rule requires
that lenders that offer loans with
prepayment penalties also offer loans
without such penalties (see 12 CFR
1026.43(g)(3)). As of January 21, 2015,
all small lenders 4 would have to be
prepared to offer loans without
prepayment penalties and, therefore, be
prepared to bear, or transfer, the cost of
interest (or more) from the prepayment
date to the end of the month.
4 Of HUD’s 1,459 supervised lenders, 598 are
considered, by HUD, to be ‘‘small supervised
lenders.’’ HUD defines ‘‘small supervised lenders’’
as those depository institutions regulated by the
Federal Reserve, the Office of the Comptroller of the
Currency, the Federal Deposit Insurance
Corporation, or the National Credit Union
Administration that have a depository asset base of
less than $500 million.
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Under this final rule, those borrowers
who would pay post-payment interest
under the previous regulations will be
expected to pay a slightly higher rate for
FHA-insured financing, but they will
also receive full benefit from lower
interest costs when they prepay later, in
most cases more than offsetting the cost
of the higher rate. Borrowers who
avoided paying post-payment interest
under the previous regulations,
however, face the slightly higher rate for
FHA-insured financing and receive no
offsetting post-payment interest savings.
Since HUD expects the increase in the
pricing of FHA-insured loans under the
proposed rule to be set to compensate
lenders for the loss of post-payment
interest from borrowers, the primary
effect of this final rule is a transfer of
funds from those who would not prepay
mid-month under the current rule to
those who would.
Accordingly, the undersigned certifies
that this rule will not have a significant
economic impact on a substantial
number of small entities.
local, and tribal governments, and on
the private sector. This rule would not
impose any Federal mandates on any
state, local, or tribal governments, or on
the private sector, within the meaning of
the UMRA.
Environmental Impact
The rule does not direct, provide for
assistance or loan and mortgage
insurance for, or otherwise govern or
regulate, real property acquisition,
disposition, leasing, rehabilitation,
alteration, demolition, or new
construction, or establish, revise or
provide for standards for construction or
construction materials, manufactured
housing, or occupancy. Accordingly,
under 24 CFR 50.19(c)(1), this rule is
categorically excluded from
environmental review under the
National Environmental Policy Act of
1969 (42 U.S.C. 4321).
List of Subjects in 24 CFR Part 203
Hawaiian Natives, Home
improvement, Indians-lands, Loan
programs-housing and community
development, Mortgage insurance,
Reporting and recordkeeping
requirements, Solar energy.
Accordingly, for the reasons
discussed in this preamble, HUD
amends 24 CFR part 203 as follows:
Executive Order 13132, Federalism
Executive Order 13132 (entitled
‘‘Federalism’’) prohibits an agency from
publishing any rule that has federalism
implications if the rule either (i)
imposes substantial direct compliance
costs on state and local governments
and is not required by statute, or (ii)
preempts state law, unless the agency
meets the consultation and funding
requirements of section 6 of the
Executive order. This rule does not have
federalism implications and does not
impose substantial direct compliance
costs on state and local governments or
preempt state law within the meaning of
the Executive order.
Unfunded Mandates Reform Act
Title II of the Unfunded Mandates
Reform Act of 1995 (2 U.S.C. 1531–
1538) (UMRA) establishes requirements
for Federal agencies to assess the effects
of their regulatory actions on state,
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Catalog of Federal Domestic Assistance
The Catalog of Federal Domestic
Assistance number for Mortgage
Insurance-Homes is 14.117.
Paperwork Reduction Act
This rule reduces information
collection requirements already
submitted to the Office of Management
and Budget (OMB) under the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501–
3520). In accordance with the
Paperwork Reduction Act, an agency
may not conduct or sponsor, and a
person is not required to respond to, a
collection of information unless the
collection displays a currently valid
OMB control number. The cost savings
of this rule, in time, are estimated to be
0.0036 burden hours.
PART 203—SINGLE FAMILY
MORTGAGE INSURANCE
1. The authority citation for 24 CFR
part 203 continues to read as follows:
■
Authority: 12 U.S.C. 1709, 1710, 1715b,
1715z-16, 1715u, and 1717z–21; 42 U.S.C.
3535(d).
2. Revise the last sentence of § 203.9
to read as follows:
■
§ 203.9 Disclosure regarding interest due
upon mortgage prepayment.
* * * This paragraph shall apply to
any mortgage executed after August 22,
1991, and before January 21, 2015.
■ 3. Revise § 203.22(b) to read as
follows:
§ 203.22 Payment of insurance premiums
or charges; prepayment privilege.
*
*
*
*
*
(b) Prepayment privilege. The
mortgage shall contain a provision
permitting the mortgagor to prepay the
mortgage in whole or in part at any time
and in any amount. The mortgage shall
not provide for the payment of any
charge on account of such prepayment.
■ 4. Revise § 203.558 to read as follows:
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§ 203.558
Federal Register / Vol. 79, No. 165 / Tuesday, August 26, 2014 / Rules and Regulations
Handling prepayments.
(a) Handling prepayments for FHAinsured mortgages closed on or after
January 21, 2015. With respect to FHAinsured mortgages closed on or after
January 21, 2015, notwithstanding the
terms of the mortgage, the mortgagee
shall accept a prepayment at any time
and in any amount. The mortgagee shall
not require 30 days’ advance notice of
prepayment, even if the mortgage
instrument purports to require such
notice. Monthly interest on the debt
must be calculated on the actual unpaid
principal balance of the loan as of the
date the prepayment is received, and
not as of the next installment due date.
(b) Handling prepayments for FHAinsured mortgages closed before January
21, 2015. (1) With respect to FHA
mortgages insured before August 2,
1985, if a prepayment is offered on other
than an installment due date, the
mortgagee may refuse to accept the
prepayment until the first day of the
month following expiration of the 30day notice period as provided in the
mortgage, or may require payment of
interest to that date, but only if the
mortgagee so advises the mortgagor, in
a form approved by the Commissioner,
in response to the mortgagor’s inquiry,
request for payoff figures, or tender of
prepayment. If the installment due date
(the first day of the month) falls on a
nonbusiness day, the mortgagor’s notice
of intention to prepay or the
prepayment shall be timely if received
on the next business day.
(2) With respect to FHA mortgages
insured on or after August 2, 1985, but
closed before January 21, 2015, the
mortgagee shall not require 30 days’
advance notice of prepayment, even if
the mortgage instrument purports to
require such notice. If the prepayment is
offered on other than an installment due
date, the mortgagee may refuse to accept
the prepayment until the next
installment due date (the first day of the
month), or may require payment of
interest to that date, but only if the
mortgagee so advises the mortgagor, in
a form approved by the Commissioner,
in response to the mortgagor’s inquiry,
request for payoff figures, or tender of
prepayment.
(3) If the mortgagee fails to meet the
full disclosure requirements of
paragraphs (b)(1) and (b)(2) of this
section, the mortgagee may be subject to
forfeiture of that portion of the interest
collected for the period beyond the date
that prepayment in full was received
and to such other actions as are
provided in part 25 of this title.
(c) Mortgagee annual notice to
mortgagors. Each mortgagee, with
respect to a mortgage under this part,
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shall provide to each of its mortgagors
not less frequently than annually a
written notice, in a form approved by
the Commissioner, containing a
statement of the amount outstanding for
prepayment of the principal amount of
the mortgage. With respect to FHAinsured mortgages closed before January
21, 2015, the notice shall describe any
requirements the mortgagor must fulfill
to prevent the accrual of any interest on
the principal amount after the date of
any prepayment. This paragraph shall
apply to any outstanding mortgage
insured on or after August 22, 1991.
Dated: August 20, 2014.
Carol J. Galante,
Assistant Secretary for Housing—Federal
Housing Commissioner.
[FR Doc. 2014–20214 Filed 8–25–14; 8:45 am]
BILLING CODE 4210–67–P
DEPARTMENT OF HOUSING AND
URBAN DEVELOPMENT
24 CFR Part 203
[Docket No. FR–5744–F–02]
RIN 2502–AJ20
Federal Housing Administration (FHA):
Adjustable Rate Mortgage Notification
Requirements and Look-Back Period
for FHA-Insured Single Family
Mortgages
Office of the Assistant
Secretary for Housing—Federal Housing
Commissioner, HUD.
ACTION: Final rule.
AGENCY:
This rule revises FHA’s
regulations governing its single family
adjustable rate mortgage (ARM) program
to align FHA interest rate adjustment
and notification regulations with the
requirements for notifying mortgagors of
ARM adjustments, as required by the
regulations implementing the Truth in
Lending Act (TILA), as recently revised
by the Consumer Financial Protection
Bureau (CFPB). The final rule requires
that an interest rate adjustment resulting
in a corresponding change to the
mortgagor’s monthly payment for an
ARM have a 45-day look-back period.
The final rule also requires that the
mortgagee of an FHA-insured ARM
comply with the disclosure and
notification requirements of the 2013
TILA Servicing Rule, including at least
a 60-day but no more than 120 day
advance notice of an adjustment to a
mortgagor’s monthly payment.
DATES: Effective Date: January 10, 2015.
FOR FURTHER INFORMATION CONTACT:
Patricia J. McClung, Acting Director,
Office of Single Family Program
SUMMARY:
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Development, Office of Housing,
Department of Housing and Urban
Development, 451 7th Street SW., Room
9278, Washington, DC 20410; telephone
number 202–708–3175 (this is not a tollfree number). Persons with hearing or
speech impairments may access this
number through TTY by calling the tollfree Federal Relay Service at 800–877–
8339.
SUPPLEMENTARY INFORMATION:
I. Background—the May 8, 2014
Proposed Rule
On May 8, 2014, HUD published a
proposed rule in the Federal Register, at
79 FR 26376, to revise the look-back
period for an FHA-insured ARM from
30 to 45 days, and to require that the
mortgagee of an FHA-insured ARM
provide at least a 60-day, but no more
than 120 day, advance notice of an
adjustment to a mortgagor’s monthly
payment. This change was in response
to the final rule of the ‘‘Mortgage
Servicing Rules Under the Truth in
Lending Act (Regulation Z)’’ 1 published
as a final rule on February 14, 2013 in
the Federal Register at 78 FR 10902.
This February 2013 final rule, referred
to in this preamble as the 2013 TILA
Servicing Rule, set the ARM adjustment
notice requirement to a period of
between 60 days (minimum) and 120
days (maximum) before the newly
adjusted payment is due. Additionally,
the 2013 TILA Servicing Rule
established 45 days as the minimum
ARM look-back period.
HUD’s May 8, 2014, rule proposed to
revise the regulations in 24 CFR 203.49
to establish a 45-day look-back period
for an FHA-insured ARM, and to require
that the mortgagee of an FHA-insured
ARM provide at least a 60-day, but no
more than 120 day, advance notice of an
adjustment to a mortgagor’s monthly
payment, in conformance with the
CFPB’s regulations. In the preamble to
the 2013 TILA Servicing Rule, the CFPB
stated that FHA’s current 30-day lookback period did not provide sufficient
time to notify the mortgagor of an
interest rate and monthly payment
adjustment. To allow HUD sufficient
time to comply with the notification
requirements of the 2013 TILA
Servicing Rule, the CFPB delayed the
effective date of the notification
requirements in the 2013 TILA
Servicing Rule to January 10, 2015, for
ARMs insured by FHA with a 30-day
look-back period. Therefore, FHA1 The CFPB initially published the rule on its Web
site: https://www.consumerfinance.gov/regulations/
2013-real-estate-settlement-procedures-actregulation-x-and-truth-in-lending-act-regulation-zmortgage-servicing-final-rules/.
E:\FR\FM\26AUR1.SGM
26AUR1
Agencies
[Federal Register Volume 79, Number 165 (Tuesday, August 26, 2014)]
[Rules and Regulations]
[Pages 50835-50838]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-20214]
========================================================================
Rules and Regulations
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains regulatory documents
having general applicability and legal effect, most of which are keyed
to and codified in the Code of Federal Regulations, which is published
under 50 titles pursuant to 44 U.S.C. 1510.
The Code of Federal Regulations is sold by the Superintendent of Documents.
Prices of new books are listed in the first FEDERAL REGISTER issue of each
week.
========================================================================
Federal Register / Vol. 79, No. 165 / Tuesday, August 26, 2014 /
Rules and Regulations
[[Page 50835]]
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
24 CFR Part 203
[Docket No. FR-5360-F-02]
RIN 2502-AJ17
Federal Housing Administration (FHA): Handling Prepayments:
Eliminating Post-Payment Interest Charges
AGENCY: Office of the Assistant Secretary for Housing-Federal Housing
Commissioner, HUD.
ACTION: Final rule.
-----------------------------------------------------------------------
SUMMARY: This rule revises FHA's regulations that allow an FHA-approved
mortgagee to charge the mortgagor interest through the end of the month
in which the mortgage is being paid. The final rule allows mortgagees
to charge interest only through the date the mortgage is paid, and
prohibits the charging of interest beyond that date.
DATES: Effective Date: January 21, 2015.
FOR FURTHER INFORMATION CONTACT: Ivery Himes, Director, Office of
Single Family Asset Management, Office of Housing, Department of
Housing and Urban Development, 451 7th Street SW., Room 9172,
Washington, DC, 20410; telephone number 202-708-1672 (this is not a
toll-free number). Persons with hearing or speech impairments may
access this number through TTY by calling the toll-free Federal Relay
Service at 800-877-8339.
SUPPLEMENTARY INFORMATION:
I. Background--the March 13, 2014 Proposed Rule
On March 13, 2014, HUD published a proposed rule in the Federal
Register, at 79 FR 14200, to eliminate post-payment interest charges to
borrowers resulting from FHA's monthly interest accrual amortization
method for calculating interest. This change was responsive to the
final rule of the Consumer Financial Protection Bureau (CFPB) entitled
``Ability-to-Repay and Qualified Mortgage Standards under the Truth in
Lending Act (Regulation Z)'' (CFPB final rule) \1\, which broadly
defines ``prepayment penalty'' in closed-end transactions as the
``charge imposed for paying all or part of the transaction's principal
before the date on which the principal is due,'' thus including charges
resulting from FHA's monthly interest accrual amortization method (see
12 CFR 1026.32(b)(6)).\2\
---------------------------------------------------------------------------
\1\ This rule was first issued on the CFPB's Web page at https://files.consumerfinance.gov/f/201301_cfpb_final-rule_ability-to-repay.pdf and subsequently published in the Federal Register on
January 30, 2013, at 78 FR 6408.
\2\ Prior to enactment of the Dodd-Frank Wall Street Reform and
Consumer Protection Act (Pub. L. 111-203, approved July 21, 2010)
(Dodd-Frank Act), the Federal Reserve Board (Board) had
responsibility for lenders' compliance with the Truth in Lending Act
(TILA). (This responsibility was transferred to the CFPB in July
2011.) In a September 2009 interpretive letter to Secretary Donovan,
Board staff advised that they had not addressed whether monthly
interest accrual amortization is a prepayment penalty and,
therefore, would not prohibit such practice without further review.
(See https://www.aba.com/Compliance/Documents/da4a00df3ffb4650b7c9154adbc1418aFedLtrtoHUD2009.pdf.) In a proposed
rule published on September 24, 2010, at 75 FR 59539, the Board
proposed to amend Regulation Z, which implements TILA and the
Board's accompanying staff commentary. In this proposed rule, the
Board stated that based on further review and analysis the monthly
interest accrual amortization method should be treated as a
prepayment penalty for TILA purposes. (See 75 FR 58586.) The CFPB's
final rule on ability-to-repay continued the analysis that the Board
provided in its September 24, 2010, proposed rule and categorized
FHA's monthly interest accrual amortization method as a prepayment
penalty, but not for FHA loans consummated before January 21, 2015.
(See 78 FR 6445.) The CFPB offers examples of the monthly interest
accrual amortization method at page 78 FR 6600. In its discussion at
this page, the CFPB recognized that FHA would need rulemaking to
change this practice and the amount of time needed to complete the
rulemaking.
---------------------------------------------------------------------------
HUD's March 13, 2014, rule proposed to revise the regulations in 24
CFR 203.558 to provide that, with respect to FHA-insured mortgages
closed on or after the effective date of the proposed regulatory
amendments, and notwithstanding the terms of the mortgage, the
mortgagee shall accept a prepayment at any time and in any amount and
shall not charge a post-payment charge. The March 13, 2014, rule
proposed to require that monthly interest on the debt be calculated on
the actual unpaid principal balance of the loan as of the date the
prepayment is received and not as of the next installment due date.
While the CFPB final rule permits limited prepayment penalties for
``qualified mortgages'' (as that term is defined in the CFPB final
rule) during the first 36 months following consummation of the mortgage
(see 12 CFR 1026.43(g)), such penalties are not permitted for higher-
priced mortgage loans or for loans that have an adjustable interest
rate.\3\ As a result of these restrictions, and in order to maximize
consistency among FHA-insured single family mortgage products and
provide the same protections for all borrowers, HUD's March 13, 2014,
rule proposed to prohibit prepayment penalties in all FHA-insured
single family mortgages.
---------------------------------------------------------------------------
\3\ See HUD's March 13, 2014, proposed rule for additional
information related to this prohibition; see also 12 CFR
1026.43(g)(1)(i)(A).
---------------------------------------------------------------------------
In addition to amending Sec. 203.558, the March 13, 2014, proposed
rule offered two technical conforming changes to the regulations in 24
CFR part 203. See the March, 13, 2014, proposed rule for a greater
discussion on the technical changes.
II. This Final Rule
This final rule follows publication of the March 13, 2014, proposed
rule and adopts that proposed rule without change. The public comment
period for the proposed rule closed on May 12, 2014, and HUD received
four public comments. Section III of this preamble discusses the
comments received on the proposed rule.
III. Discussion of Public Comments Received on the March 13, 2014,
Proposed Rule
The public commenters included a mortgage company and trade
associations. Commenters were over-all supportive of HUD's proposal to
prohibit the charging of post-payment interest on FHA loans.
Comment: Maintain proposed implementation language and publish a
final rule as soon as practicable. A commenter requested that HUD
maintain the implementation language, ``closed on or after [the
effective date of the rule]'', as opposed to using case number
assignment or some other date. The commenter explained that the
technological and procedural changes needed to implement this rule will
[[Page 50836]]
require a long lead time and any change to the implementation language
may delay lenders' abilities to fully comply with the rule. The
commenter also requested that the final rule be published as soon as
practicable to provide the industry with clarity and certainty.
HUD Response: HUD appreciates the industry's support of this rule
and desire for a quick implementation, and is not making any changes to
the implementation language.
Comment: Concern that lenders will recoup the costs of not
collecting post-payment interest by charging higher interest rates or
servicing fee differential is overstated. In response to HUD's
statement in the preamble to the proposed rule that HUD expects lenders
will simply look elsewhere to recoup funds lost by not being able to
charge interest beyond the mortgage payment date, a commenter explained
that lenders continue to offer Veterans Administration (VA) and Rural
Housing Service (RHS) loans, which are securitized by Ginnie Mae and,
these loans do not have prepayment penalties, but offer interest rates
similar to current FHA rates. The commenter also stated that FHA loans
are attractive to investors, regardless of the excess interest
payments, because they carry the guarantee of the federal government.
HUD Response: The commenter raises a good point, which HUD
appreciates and hopes reflects how lenders will handle FHA-insured
loans that now prohibit post-payment interest, and that is by
continuing to offer the same interest rates that they offer now.
Comment: Publish additional information in the final rule or in a
concurrent Mortgagee Letter. A commenter asked HUD to publish revised
maximum mortgage calculations, for FHA refinance transactions, to
include the actual amount of interest to be paid and financed. The
commenter also asked that HUD consider a closing date change, and the
impact on the maximum mortgage calculation, to be included in the
existing policy for minor adjustments at closing.
HUD Response: HUD appreciates this concern, but believes the
current policy provides adequate flexibility in calculating the maximum
mortgage eligible for FHA refinance transactions. FHA policy permits
interest due on the previous mortgage to be financed into the new FHA
mortgage. The amount of interest that is permitted to be financed
varies based upon the refinance program. However, each program that
limits the financing of interest allows for a flexibility of $500 in
determining the maximum mortgage amount. HUD expects that this
flexibility provides sufficient leeway to account for changes in the
interest due on the previous mortgage as a result of changes in the
closing date.
Comment: Passing costs on to borrowers is not a consumer
protection. One commenter raised a concern that if servicers of FHA
loans continue to be obligated to pay investors charges that the
servicers may no longer collect from consumers, as required by Ginnie
Mae, originating lenders and servicers will need to price that charge
into the cost of the loan, raising costs for FHA borrowers, which is
not a consumer protection. The commenter requested that HUD, FHA,
Ginnie Mae, and the CFPB coordinate actions so that the intended
consumer protections can be implemented.
Another commenter explained that under current regulations,
borrowers could choose to avoid paying post-payment interest by paying
off the loan at the end of the month. Under the proposed rule, however,
all borrowers would have to pay more, including those borrowers who
would have strategically avoided paying post-payment interest under the
current regulations.
HUD Response: HUD appreciates this concern, but emphasizes that any
cost passed on to the consumer by the servicer, as a result of the
ability for security holders to continue to collect interest through
the end of the month, is expected to be minimal. In addition, not all
consumers will experience additional costs. For example, consumers who
would have prepaid their mortgages and would have been subject to post-
payment interest charges under FHA's regulations, prior to amendment by
this rule, will no longer be subject to those charges. These consumers
may end up paying slightly more in interest each month or a higher
servicing fee differential, but will avoid a post-payment charge when
prepaying their mortgage later on, off-setting the cost of slightly
increased interest rates or servicing fee differentials.
In addition, as another commenter mentioned, lenders continue to
offer VA and RHS loans, which are securitized by Ginnie Mae and permit
security holders to collect interest through the end of the month, but
do not allow for prepayment penalties. The interest rates on these VA
and RHS loans are similar to current FHA rates, illustrating that costs
are not being passed on to borrowers in the manner of higher interest
rates.
Comment: Pressure placed on mortgage servicers. A commenter
explains that the proposed rule would place further pressure on
mortgage servicers, at a time when servicing costs continue to rise.
The commenter explained that servicers will have higher direct costs,
and that the rule would impact the value of FHA mortgage servicing
rights.
HUD Response: HUD appreciates this concern; however, the impact on
servicers is consistent with prevailing industry practice. As discussed
previously, GSE, VA, and RHS loans do not require borrowers to pay
post-payment interest.
Comment: FHA should work with Ginnie Mae to transition to a daily
simple interest calculation structure. This structure would calculate
interest daily based on outstanding principal balance, rather than as a
predetermined monthly amount, and align the cash flows from the
underlying loans with the payments made to investors in the mortgage-
backed securities.
HUD Response: At this time, FHA declines the suggestion to work
with Ginnie Mae to transition to a daily simple interest calculation
structure. The simple interest calculation structure poses unnecessary
risks to borrowers. For example, interest accrues daily on the unpaid
principal balance instead of monthly, so there is no grace period for
payments. In addition, the loan will not fully amortize over the stated
term if the borrower makes payments later than the scheduled due date.
IV. Findings and Certifications
Regulatory Review--Executive Orders 12866 and 13563
Under Executive Order 12866 (Regulatory Planning and Review),
agencies must determine whether a regulatory action is significant and,
therefore, subject to review by the Office of Management and Budget
(OMB) in accordance with the requirements of the order. Executive Order
13563 (Improving Regulations and Regulatory Review) directs executive
agencies to analyze regulations that are ``outmoded, ineffective,
insufficient, or excessively burdensome, and to modify, streamline,
expand, or repeal them in accordance with what has been learned.''
Executive Order 13563 also directs that, where relevant, feasible, and
consistent with regulatory objectives, and to the extent permitted by
law, agencies are to identify and consider regulatory approaches that
reduce burdens and maintain flexibility and freedom of choice for the
public. At the proposed rule stage, this document was determined to be
a ``significant regulatory action'' as defined in section 3(f) of the
Executive order (although not
[[Page 50837]]
an economically significant regulatory action, as provided under
section 3(f)(1) of the Executive order). While this rule remains a
significant regulatory action, HUD is adopting the proposed rule
without change, and therefore further review of this rule under EO
12866 is not necessary. Additionally, the regulatory impact of this
rule, specifically the costs and benefits of this rule, as presented in
the preamble to the proposed rule at 79 FR 14202 through 14203 remain
applicable to this rule.
Regulatory Flexibility Act
The Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et seq.)
generally requires an agency to conduct a regulatory flexibility
analysis of any rule subject to notice and comment rulemaking
requirements, unless the agency certifies that the rule will not have a
significant economic impact on a substantial number of small entities.
As noted above in this preamble, even without rulemaking by HUD, the
circumstances in which a small entity could charge a prepayment penalty
have been significantly limited by the CFPB final rule. The CFPB final
rule implements the Dodd-Frank Act provisions that generally prohibit
prepayment penalties except for certain fixed-rate, qualified mortgages
where the penalties satisfy certain restrictions and the creditor has
offered the consumer an alternative loan without such penalties. The
CFPB final rule categorizes the post-payment interest charge resulting
from FHA's monthly interest accrual amortization method as a prepayment
penalty. Therefore, the use of post-payment interest charges on all FHA
loans closed on or after January 21, 2015, will be considered
prepayment penalties. This is true, irrespective of any economic
impacts of the rule.
In any event, even if HUD were to issue a rule allowing prepayment
penalties, the CFPB final rule requires that lenders that offer loans
with prepayment penalties also offer loans without such penalties (see
12 CFR 1026.43(g)(3)). As of January 21, 2015, all small lenders \4\
would have to be prepared to offer loans without prepayment penalties
and, therefore, be prepared to bear, or transfer, the cost of interest
(or more) from the prepayment date to the end of the month.
---------------------------------------------------------------------------
\4\ Of HUD's 1,459 supervised lenders, 598 are considered, by
HUD, to be ``small supervised lenders.'' HUD defines ``small
supervised lenders'' as those depository institutions regulated by
the Federal Reserve, the Office of the Comptroller of the Currency,
the Federal Deposit Insurance Corporation, or the National Credit
Union Administration that have a depository asset base of less than
$500 million.
---------------------------------------------------------------------------
Under this final rule, those borrowers who would pay post-payment
interest under the previous regulations will be expected to pay a
slightly higher rate for FHA-insured financing, but they will also
receive full benefit from lower interest costs when they prepay later,
in most cases more than offsetting the cost of the higher rate.
Borrowers who avoided paying post-payment interest under the previous
regulations, however, face the slightly higher rate for FHA-insured
financing and receive no offsetting post-payment interest savings.
Since HUD expects the increase in the pricing of FHA-insured loans
under the proposed rule to be set to compensate lenders for the loss of
post-payment interest from borrowers, the primary effect of this final
rule is a transfer of funds from those who would not prepay mid-month
under the current rule to those who would.
Accordingly, the undersigned certifies that this rule will not have
a significant economic impact on a substantial number of small
entities.
Environmental Impact
The rule does not direct, provide for assistance or loan and
mortgage insurance for, or otherwise govern or regulate, real property
acquisition, disposition, leasing, rehabilitation, alteration,
demolition, or new construction, or establish, revise or provide for
standards for construction or construction materials, manufactured
housing, or occupancy. Accordingly, under 24 CFR 50.19(c)(1), this rule
is categorically excluded from environmental review under the National
Environmental Policy Act of 1969 (42 U.S.C. 4321).
Executive Order 13132, Federalism
Executive Order 13132 (entitled ``Federalism'') prohibits an agency
from publishing any rule that has federalism implications if the rule
either (i) imposes substantial direct compliance costs on state and
local governments and is not required by statute, or (ii) preempts
state law, unless the agency meets the consultation and funding
requirements of section 6 of the Executive order. This rule does not
have federalism implications and does not impose substantial direct
compliance costs on state and local governments or preempt state law
within the meaning of the Executive order.
Unfunded Mandates Reform Act
Title II of the Unfunded Mandates Reform Act of 1995 (2 U.S.C.
1531-1538) (UMRA) establishes requirements for Federal agencies to
assess the effects of their regulatory actions on state, local, and
tribal governments, and on the private sector. This rule would not
impose any Federal mandates on any state, local, or tribal governments,
or on the private sector, within the meaning of the UMRA.
Catalog of Federal Domestic Assistance
The Catalog of Federal Domestic Assistance number for Mortgage
Insurance-Homes is 14.117.
Paperwork Reduction Act
This rule reduces information collection requirements already
submitted to the Office of Management and Budget (OMB) under the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520). In accordance
with the Paperwork Reduction Act, an agency may not conduct or sponsor,
and a person is not required to respond to, a collection of information
unless the collection displays a currently valid OMB control number.
The cost savings of this rule, in time, are estimated to be 0.0036
burden hours.
List of Subjects in 24 CFR Part 203
Hawaiian Natives, Home improvement, Indians-lands, Loan programs-
housing and community development, Mortgage insurance, Reporting and
recordkeeping requirements, Solar energy.
Accordingly, for the reasons discussed in this preamble, HUD amends
24 CFR part 203 as follows:
PART 203--SINGLE FAMILY MORTGAGE INSURANCE
0
1. The authority citation for 24 CFR part 203 continues to read as
follows:
Authority: 12 U.S.C. 1709, 1710, 1715b, 1715z-16, 1715u, and
1717z-21; 42 U.S.C. 3535(d).
0
2. Revise the last sentence of Sec. 203.9 to read as follows:
Sec. 203.9 Disclosure regarding interest due upon mortgage
prepayment.
* * * This paragraph shall apply to any mortgage executed after
August 22, 1991, and before January 21, 2015.
0
3. Revise Sec. 203.22(b) to read as follows:
Sec. 203.22 Payment of insurance premiums or charges; prepayment
privilege.
* * * * *
(b) Prepayment privilege. The mortgage shall contain a provision
permitting the mortgagor to prepay the mortgage in whole or in part at
any time and in any amount. The mortgage shall not provide for the
payment of any charge on account of such prepayment.
0
4. Revise Sec. 203.558 to read as follows:
[[Page 50838]]
Sec. 203.558 Handling prepayments.
(a) Handling prepayments for FHA-insured mortgages closed on or
after January 21, 2015. With respect to FHA-insured mortgages closed on
or after January 21, 2015, notwithstanding the terms of the mortgage,
the mortgagee shall accept a prepayment at any time and in any amount.
The mortgagee shall not require 30 days' advance notice of prepayment,
even if the mortgage instrument purports to require such notice.
Monthly interest on the debt must be calculated on the actual unpaid
principal balance of the loan as of the date the prepayment is
received, and not as of the next installment due date.
(b) Handling prepayments for FHA-insured mortgages closed before
January 21, 2015. (1) With respect to FHA mortgages insured before
August 2, 1985, if a prepayment is offered on other than an installment
due date, the mortgagee may refuse to accept the prepayment until the
first day of the month following expiration of the 30-day notice period
as provided in the mortgage, or may require payment of interest to that
date, but only if the mortgagee so advises the mortgagor, in a form
approved by the Commissioner, in response to the mortgagor's inquiry,
request for payoff figures, or tender of prepayment. If the installment
due date (the first day of the month) falls on a nonbusiness day, the
mortgagor's notice of intention to prepay or the prepayment shall be
timely if received on the next business day.
(2) With respect to FHA mortgages insured on or after August 2,
1985, but closed before January 21, 2015, the mortgagee shall not
require 30 days' advance notice of prepayment, even if the mortgage
instrument purports to require such notice. If the prepayment is
offered on other than an installment due date, the mortgagee may refuse
to accept the prepayment until the next installment due date (the first
day of the month), or may require payment of interest to that date, but
only if the mortgagee so advises the mortgagor, in a form approved by
the Commissioner, in response to the mortgagor's inquiry, request for
payoff figures, or tender of prepayment.
(3) If the mortgagee fails to meet the full disclosure requirements
of paragraphs (b)(1) and (b)(2) of this section, the mortgagee may be
subject to forfeiture of that portion of the interest collected for the
period beyond the date that prepayment in full was received and to such
other actions as are provided in part 25 of this title.
(c) Mortgagee annual notice to mortgagors. Each mortgagee, with
respect to a mortgage under this part, shall provide to each of its
mortgagors not less frequently than annually a written notice, in a
form approved by the Commissioner, containing a statement of the amount
outstanding for prepayment of the principal amount of the mortgage.
With respect to FHA-insured mortgages closed before January 21, 2015,
the notice shall describe any requirements the mortgagor must fulfill
to prevent the accrual of any interest on the principal amount after
the date of any prepayment. This paragraph shall apply to any
outstanding mortgage insured on or after August 22, 1991.
Dated: August 20, 2014.
Carol J. Galante,
Assistant Secretary for Housing--Federal Housing Commissioner.
[FR Doc. 2014-20214 Filed 8-25-14; 8:45 am]
BILLING CODE 4210-67-P