On 11/13/2009, HUD issued release No. 09-215 indicating that for the first 4 months of 2010 they would "exercise restraint in enforcing new regulatory requirements under RESPA, due to take full effect Jan. 1, 2010."
Has anyone been examined during this time period and what was the approach of the examiners? Despite our Bank's significant and documented good faith efforts to comply, our OCC exam team completely disregarded those efforts and treated a handful of HE loans that provided the 'old' GFE as violations of RESPA. (As of this date, we are finally in full compliance.)
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