We're treating compliance with GAFLA as we do all other state requirements.
Federally chartered thrifts in Georgia caught what looks like a break from GAFLA when the Office of Thrift Supervision (OTS) pointed out in a January opinion letter that Congress gave OTS, and not the states, "the task of determining the best practices for thrift institutions.
Comptroller of the Currency (OCC) was collecting comments on whether or not to exempt banks from GAFLA.
Even if revisions to GAFLA remove the assignee provision, there's still plenty in the law to make a mortgage banker reach for the TUMS[R].
The reasonable, tangible net benefit provision of GAFLA applies to loans refinanced within five years of origination.
If the borrower's original loan has special terms, say down payment assistance, GAFLA mandates that the lender must know about those benefits.
Countrywide's Seebach also predicts that predatory lending laws could change the landscape somewhat in the secondary market if more laws like GAFLA get enacted in other jurisdictions.
Others argue that GAFLA will cause very few problems outside the subprime market.