Earlier this year the Office of Thrift Supervision (OTS) solicited comments on a new proposed schedule for Annual Supplemental Consolidated Data on Reverse Mortgages for its Thrift Financial Report (TFR).
According to the OTS, collecting this information will provide the necessary information for policy development and the management of risk exposures posed by thrifts involvement with reverse mortgages.
The OTS received one comment from an organization which had no concerns with the new schedule, except for the items relating to the reporting of the estimated number of fee-paid referrals for reverse mortgages.
The organization asked the OTS to reconsider this reporting requirement because it may require thrifts to report information that is inconsistent with the legal requirements of the Real Estate Settlement Procedures Act (RESPA).
The OTS acknowledged that its description of this proposed reporting requirement could be viewed in this manner. Accordingly, to avoid possible misinterpretation or misunderstanding, OTS is revising its proposed annual data items for the reporting of the number of fee-paid referrals during the year.
As revised, thrifts would annually report the number of reverse mortgage loan referrals to other lenders during the year from whom they have received any compensation for services performed in connection with the origination of reverse mortgages.
The revised referral data items would be implemented beginning December 31, 2010. The other proposed reverse mortgage data items would be implemented as proposed beginning on the same date.