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The Federal Reserve Board (FRB) submitted a plan to redraft the escrow account requirements for higher-priced, first lien “jumbo” mortgage loans. It uses a provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act, and would increase the annual percentage rate (APR) threshold used to establish whether a mortgage lender is required to establish an escrow account for property taxes and insurance for first-lien jumbo mortgage loans. In the United States, a jumbo mortgage is a mortgage loan in an amount above conventional conforming loan limits.

In July 2008, the Board issued final rules requiring creditors to establish escrow accounts for first-lien loans if a loan’s APR is 1.5 percentage points or more above the applicable prime offer rate. Under the Dodd-Frank Act, which amended the Truth-in-Lending Act (TILA), the escrow requirement will apply for jumbo loans only if the loan’s APR is 2.5 percentage points or more above the applicable prime offer rate. The APR threshold for non-jumbo loans stayed the same.

The Dodd-Frank Act incorporates into TILA the Board’s regulatory requirement for escrow accounts and revises the APR threshold, but the act also includes other provisions, including new disclosure requirements. This change would implement only the act’s modification to the APR threshold. Other provisions of the act concerning escrow accounts will be fulfilled in a separate rulemaking.

The proposed change would not affect the APR threshold used to determine whether a jumbo loan is subject to the other consumer protections that the Board adopted for higher-priced loans in 2008. Those protections include requirements for determining consumers’ repayment abilities and restrictions on pre-payment penalties.

The Board is soliciting comment on the proposed rule, including the appropriate implementation date, for 30 days after publication in the Federal Register.

Trying to make sense of it all? Contact someone who is the expert in jumbo loans.

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The newest drop in rates doesn’t seem to be doing much for conventional loans, but for jumbo loans it is a different matter. Those at higher income levels might not be as worried about jobs as others. Currently it seems that the best hope for the housing market is to keep these rates lower. Now big banks are joining the charge to give out jumbo loans. Mortgage brokers are still more qualified to handle your jumbo loan.

How low are the current jumbo rates? Last year at this time, a 30-year fixed jumbo rate was averaging more than 6 percent. It’s now at an all time low average of 5.07 percent. And the re-finance rate for a 30 year jumbo is currently at 5.30 percent. A fifteen year jumbo is at the historic low average of 4.68 percent.

The market has shifted from one extreme to the other; now lenders require high-net borrowers to put down as much as 40 or 50 percent for a down payment compared to only 20 percent a few years ago. Borrowers must also have good income, strong credit scores of 700 or better and sufficient financial reserves. In addition these creditworthy buyers are waiting longer to close their jumbo mortgages while banks intensely study financial documents and complete their due diligence. Low and no down payment and adjustable rate schemes are no more.

The biggest mortgage players —  agencies Freddie Mac and Fannie Mae — increased conforming loan limits from $417,000 to $729,750, cutting more than $312,000 off the jumbo market that once was the optimal area of gain for brokers. The sky may be lightening however, credit is relaxing , interest rates are low again, new creative loan plans are making an appearance and repressed demand for high-end housing is anxious to enter the market. Unlike conventional mortgages, jumbo loans by definition exceed the conforming loan limit of $417,000 set by Fannie Mae and Freddie Mac. Jumbo rates are loosely tied to long term treasuries but they are traditionally higher because of the risk involved for the banks in making a larger loan. Strict or not, the banks are lending and refinancing jumbo loans at much higher volumes than last year.

If you are looking to get into a jumbo rate mortgage or are interested in refinancing your current jumbo loan please contact the jumbo loan expert.

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