With all the talk recently about quality and compliance, we need talk about if a lender has an adequate written Quality Control Policy. Do you? Whether you are outsourcing QC or performing it internally, a lender must have a written plan. This policy must clearly outline the scope of what a lender wants, and needs, to ensure their loans are…
It seems to me like only yesterday when a brand new method of determining a borrower’s creditworthiness was introduced. It was dubbed a “credit score”. It would revolutionize lending. No longer would underwriters need to sweat and labor reviewing the details of an applicant’s credit history and profile. Like Prego, it’s in there. All the necessary ingredients to determine a…
Another day, another DOJ settlement under a False Claims Action brought against a major Bank originating FHA loans. This time, it’s M&T Bank Corp to the tune of $64 million. Not a happy tune. Here we go again. DOJ alleged that M&T did not originate their FHA loans in compliance will all FHA rules and requirements. Rather than fight these…
As I’m sure if you’ve heard by now, many banks are shying away from FHA lending. As a direct result, independent, non-bank, mortgage lenders are seeing a windfall in these loans. The old “bad news; good news” scenario. Is this good news for independents? Banks fear the potential repercussions resulting from the certifications required by FHA when doing these FHA-insured…
For years, lenders were required to perform a quality control review of the loans they closed. Today, lenders need to perform both the post-closing QC review but must also conduct reviews on loans prior to the closing. These required pre and post-closing quality reviews present a great opportunity for lenders to identify potential problems, and they help to indicate where…
The other day, I wrote about the TRID panel I moderated at our recent inaugural LoanLogics’ User’s Conference at the Sawgrass Marriott in Florida. During that presentation, Noerena Limon, Quality Analyst with the CFPB, mentioned, on more than one occasion, the importance of consumer education and what CFPB expects from a lender and is doing to help. I mentioned that…
