1 The National Association of Mortgage Brokers, and other sources, state that over 50 percent of home loans are originated by mortgage brokers.2 The Real Estate Settlement and Procedures Act (RESPA) prohibits kickbacks or unearned referral fees that tend to unnecessarily increase the cost of certain settlement services. 3 There is no federal licensing or continuing education requirements for mortgage brokers or correspondents. Whether a broker or correspondent is required to be licensed is established by each state with each state setting its own licensing standards.4 Federal Credit Unions cannot impose prepayments penalties on loans they grant or enforce a prepayment penalty that may exist in a loan contract they participate in or purchase, per 12 U.S.C. 107(5)(A)(viii) of the Federal Credit Union Act, 701.21(c)(6) of the NCUA Rules and Regulations, and further discussed in existing NCUA legal opinions. Whether loan prepayment penalties are allowed for state chartered credit unions is determined at the state level. 5 Letter to Credit Unions 07-CU-09, Subprime Mortgage Lending, includes an Interagency Statement which addresses, among other concerns, risk considerations associated with predatory lending. OCC Advisory Letter AL 2003-3 referenced above also provides detail regarding applicable compliance laws and guidance on avoiding predatory or abusive lending.6 Board policies need to address such issues as: frequent, sequential refinancings with little to no economic benefit to the borrower, negatively amortizing loans, prepayment penalties that are not limited to the early years of the loans, financing points, fees, penalties, and other charges, allowing non-owner occupied property financing, and balloon payments in short-term transactions. 7 Delegation of those authorities to a third party would be a violation of 113 of the FCU Act for federal credit unions, and an unsafe and unsound practice for all federally-insured credit unions, which could be subject to possible NCUA action under 206 of the FCU Act.
OPM, under its own statutory and regulatory authority, requires agencies submit to OPM, within 10 days of issuance, any arbitration awards under 5 U.S.C. 7121(e ) and (f) relating to actions taken under Chapter 43 and Chapter 75, United States Code, for analysis in accordance with OPM's authority under 5 U.S.C 7703(d). OPM also requires that other arbitration awards must be submitted within 30 days of issuance. Agencies should also provide OPM with copies of collective-bargaining agreements. This promotes transparency by allowing the public to view the types of agreements reached between agencies and Federal sector unions.
New delegated authority could sink DOD unions
EPA delegated authority for the NPDES permitting program to the Missouri Department of Natural Resources. Under this authority, Missouri published its own stormwater regulations (10 CSR 20-6.200) in 1992. The Standard Industrial Classification (SIC) system describes 11 industrial categories, covering 30 sectors of activity, that are required to obtain stormwater discharge permits. Recently a more detailed classification system, the North American Industry Classification System, was established. Facilities review either system to choose one code based on its main type of activity or income source. If a facility has all industrial activities not exposed to stormwater, they may request a no exposure certification instead of a permit. 2ff7e9595c
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