Reminder on Idaho Transportation Department’s New Vehicle System

Cars speed by on a freeway.12/15/2020

The Idaho Transportation Department deployed its new GEM vehicle system in October. This system now requires owner and vehicle information for every transitional ownership document (TOD) filing, even for transactions that simply involve refinancing a loan or perfecting a lien on a vehicle used as collateral. For these transactions, lenders are now being asked to submit with the TOD form ITD 3901, an application for certificate of title, form ITD 3337 that lists owner information, and all vehicle information including color and odometer reading, status and date.

The updated TOD form and the title application form are available as fillable templates at Select the “Registration/Plates” tab, and then scroll down and select “Forms & Publications.” Please ensure a copy of a title application is included with every TOD filing, as the transaction cannot be processed without it.

Question of the Week

Q. Regarding death of member account. The executor/personal representative of the estate of our deceased member would like to close account. However, this account has a beneficiary so the funds in this particular account go to the beneficiary, but can we give that information to the executor?

A. You may inform the executor/personal representative (PR) that there is a beneficiary to the account. As the person responsible for settling the estate, the PR is entitled to information about the account prior to the death of the member. This would include information from the signature card showing the designation of the beneficiary. The beneficiary is the person who is entitled to the funds in the account. If the PR wishes to fight that, they can take it to court.

Legal Briefs

Consumer Financial Protection Bureau

CFPB Releases Final Rule Amendment to General QM Loan Definition
The CFPB released a final rule which will update the general definition of Qualified Mortgages in Regulation Z. The rule change will replace the current 43% DTI with price-based thresholds.

CFPB Releases Final Rule Creating New Seasoned QM Loans
The CFPB released a final rule to create a new category of Qualified Mortgages. The new seasoned QMs have certain requirements and become QMs after a three-year seasoning period.

Federal Housing Finance Agency

FHFA Further Extends COVID-Related Loan Flexibilities
The FHFA extended several loan origination flexibilities until Jan. 21.

Washington Department of Financial Institutions

DFI Winter 2020/2021 Newsletter
The DFI released its Winter 2020/2021 newsletter, which contains several articles of interest.

Office of Foreign Assets Control

OFAC has updated the SDN list as of Dec. 14. The last update prior to this was Dec. 8.

Posted in Compliance News, Compliance News.