Mortgage Industry Trends

FHA Reports “No Progress in Lender Defects”

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cure-lender-defects-earlierBased on FHA’s most recent Lender Insight newsletter (Insights), FHA lenders are not doing so well in managing their initial gross defects.

According to the FHA’s post-endorsement technical reviews, over the past 2 years, the initial unacceptable defect rate is averaging just south of 50%. That means that about half of the loans delivered for FHA insurance have substantial defects.

The good news is that the net defect rate is running at a monthly average of just about 6%, which is well below the initial gross rate. This indicates that lenders are curing somewhere around 44% of the defects.

The question is: “Why does this keep happening month after month?” FHA is concerned. They will begin to carefully analyze how lenders are addressing the causes of these initial defects. And, try to determine why they cannot provide FHA with the required information or documentation with their initial file submissions.

For your info, the referenced Lender Insights highlights the top 5 gross defects FHA is experiencing. These may be a good starting point for your reviews

It is evident by the final net defect rate that most lenders can cure the problems. They need to develop and implement action plans to review files to identify these problem areas and the missing information prior to the FHA submissions. This way they can make the cures before delivering an incomplete file and risking the wrath of FHA.

Pre and post-closing audits with defect reporting and related plans for corrective action are essential.  As I’ve said before (and will keep on saying), you are required to perform these audits, why not get the biggest benefit for the cost and effort?

Quality counts. FHA will not continue to tolerate this poor performance. Don’t wait for them to take action. Get ahead of the curve and set your action plans in motion. It’s well worth the effort.

LoanLogics is standing by to assist.

Michael Vitali

About the Author

Michael Vitali

Michael L. Vitali – Independent Consultant to the Mortgage Industry Mike Vitali is an independent consultant to the mortgage industry on matters concerning compliance and mortgage lending. He most recently served as the Senior Vice President and Chief Compliance Officer for LoanLogics, monitoring regulatory developments and their practical implications for the mortgage lending industry. His duties included research, interpretation, and analysis of existing and proposed legislation related to the industry in support of recommendations for policy and/or procedure changes to maintain continued quality and compliance with all applicable laws, rules and regulations, investor requirements, and standard mortgage practices. In his more than 40 years in the mortgage industry, in senior level management, he has gained experience in all areas of mortgage lending, risk management, and compliance. Mike is a past President of the MBA of Greater Philadelphia, is a charter member and was the second Chairman of the MBA of Pennsylvania, and a past board member and Legislative Chair of both associations. He is a recipient of the 1998 Mortgage Banker of the Year Award from the MBA of Greater Philadelphia, and the 2003 Chairman's Award from the MBA of PA, and currently serves on several compliance related task forces for MBA.
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Michael Vitali

About Michael Vitali

Michael L. Vitali – Independent Consultant to the Mortgage Industry Mike Vitali is an independent consultant to the mortgage industry on matters concerning compliance and mortgage lending. He most recently served as the Senior Vice President and Chief Compliance Officer for LoanLogics, monitoring regulatory developments and their practical implications for the mortgage lending industry. His duties included research, interpretation, and analysis of existing and proposed legislation related to the industry in support of recommendations for policy and/or procedure changes to maintain continued quality and compliance with all applicable laws, rules and regulations, investor requirements, and standard mortgage practices. In his more than 40 years in the mortgage industry, in senior level management, he has gained experience in all areas of mortgage lending, risk management, and compliance. Mike is a past President of the MBA of Greater Philadelphia, is a charter member and was the second Chairman of the MBA of Pennsylvania, and a past board member and Legislative Chair of both associations. He is a recipient of the 1998 Mortgage Banker of the Year Award from the MBA of Greater Philadelphia, and the 2003 Chairman's Award from the MBA of PA, and currently serves on several compliance related task forces for MBA.
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