Mortgage Loan Quality

Are You Just a Defect Monitor?

Defect-Monitor-action-plan-bank-guard
0 0
Read Time:2 Minute, 15 Second

Defect-Monitor-action-plan-bank-guardYou’ve probably seen the commercials on TV with a bank security guard or a guy looking like a dentist, where they say they are just a ‘monitor’ but don’t do anything about what they find. It’s funny for a commercial, but not so funny to the bank or the patient needing dental work.

Today, with so much emphasis placed on loan defects, quality, and compliance, it’s important that any QC program is more than a defect monitor.

It’s great to perform timely and complete audits to identify defects, but that’s only half the battle. Something must be done to correct the defects and ensure that they do not continue.

That something is an action plan. That action plan is a process whereby once defects are identified; they may be tracked toward correction.

An action plan identifies trends and patterns in loan defects that can point to the source of the defects and indicates what needs to be done toward immediate correction and long-term resolution.

Some defects may be isolated instances, oversights, or a temporary lapse in judgment. Others may be indicative of major problems lurking just below the surface.

Like termite infestation, if not identified early and corrected, the damage can be quite costly. You can’t let defects eat away at your loan originations and your profits.

Your complete, written, and documented QC program should consist of a process that:

  • Selects an ample number of loans each month for review which adequately represents the main areas of originations, their risk, and exposure;
  • Provides a thorough due diligence review of the loans selected;
  • Reports defects in detail, by area and severity. Showing how they would affect the loan’s performance and ability to be sold;
  • Identifies the sources of loans with defects and the sources of the defects found;
  • Selects additional loans from the pipeline for review based on the defects found in your initial loan reviews;
  • Includes complete monthly reporting package to Senior Management and to each area responsible, identifying  the loans with defects;
  • Provides a written Action Plan identifying:
    • The type of defects
    • The source
    • The process and activities taken toward correction
    • Follow up and progress reporting until final resolution.

 

Having just a defect monitor is simply not enough. You must have a complete system that quickly identifies potential problems, and then initiates the follow-up needed to correct the problems and to make sure they don’t occur again.

Monitor your loans and take the appropriate action on defects. Otherwise, the defects will result in action being taken against you!

Don’t let untreated defects rob you of your profits or decay your pipeline.

Stay diligent my friends.

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.
Tagged , , ,
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.
View all posts by Michael Vitali →