Mortgage Compliance

“TOTAL” Will Not Provide MIPs

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FHA-TOTAL-new-rulesIn case you missed it, on June 8th FHA announced that their TOTAL (Technology Open To Approved Lenders) automated underwriting system will no longer provide the upfront or annual mortgage insurance premium factors required for a loan (FHA Info #16-36).

These factors may be found in Appendix I to the new FHA Single Family Housing Policy Handbook 4000.1 (Handbook).

This means the feedback returned to the AUS system used will not reflect any FHA mortgage insurance factors for the loan submitted. It is up to the lender to ensure the correct initial and annual premiums are charged and collected.

Maybe, FHA is planning to make some changes to these factors and wants to avoid the need to reprogram systems each time a change is made. If so, let’s hope it’s for the better.

In addition, as of June 11th , FHA now requires a lender to report, through TOTAL, whether a borrower had received counseling from a HUD Approved Counseling Agency for all loans. When this information is not properly entered a default value of “Not Counseled” will be returned by the AUS used when sending the case file to FHA’s TOTAL Scorecard.

One last change is to the range of allowable LTVs. The new allowable LTVs will be in a range from greater than .10% up to 125%.

The game keeps changing…TOTALLY!

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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