Everyone is well aware of the requirements of the new TRID rules and the related challenges in issuing the new forms, accurately and timely. There are some serious concerns in the Secondary Markets that minor issues, like fees not placed in the proper order, decimal places not carried out correctly, and/or misspellings on documents, along with missed timing of disclosure…
Author: Michael Vitali
Happy New Year: CFPB Lays Out 2016 Audit Targets
As Private Gomer Pyle would say to Sargent Carter, “Surprise, surprise, surprise!” It shouldn’t be a big surprise to mortgage lenders that one of the CFPB’s top priorities when performing audits in 2016 will be to carefully review and analyze all LO compensation plans (CFPB Audits). This has been an ongoing concern of the CFPB. They want to ensure that…
It’s Not Only LO Comp Plans That May Cause You Trouble
In the past, we’ve heard and read about Lenders being fined and penalized for violations which relate to their LO compensation plan and/or for some method that they pay their loan originators. Based on recent DOJ settlements with FHA lenders, problems may also arise resulting from FHA Underwriter comp plans. In the case of Franklin American Mortgage, of Franklin, TN,…
Are We Destined to Repeat History
Let’s not go jumping to any conclusions here, but San Francisco Federal Credit Union just announced a zero down payment loan for home purchases that will go as high as $2 million. Yup, you read it right, no down to $2 million! It’s a 5/5 year adjustable rate with a present start rate at 4% plus a 1 point origination…
Is it Tight Credit Standards or Just Prudent Lending?
Some experts believe that a slight rate hike may actually increase lending by loosening credit standards (Rate Hike). They believe the higher rates will entice lenders to make it a little easier for people to get mortgages. Is that because the higher rates may restrict some at the lower end of the scale from affording a home? So, in turn,…
Walking a Thin Line on Disability Income Verification
Should a lender ask an FHA loan applicant the nature of their disability and how long they expect to be receiving any benefits? Be careful. A Michigan lender had to enter into an agreement with HUD to settle alleged discrimination against an applicant with a disability. Under this agreement the lender, Mortgage One, is required to make a monetary settlement…