Latest posts by Rob Chrisman (see all)
- May 23: AE & CFO jobs, new products; HMDA training; misc. updates around the biz on policies, procedures, documentation - May 23, 2017
- May 22: LO & AE jobs, lenders expanding; FHA & VA news and lender trends – households moving toward buying - May 22, 2017
- May 20: Letters & notes on the MID, new FinCEN rule for financial institutions, and a cybercrime primer - May 20, 2017
Here’s a little trivia for you. This week I am in Minnesota and Kansas, but 4,000 miles away not a single one of the country’s ten biggest banks, including Bank of America, Chase, Citi, and Wells Fargo, has a retail location in Hawaii! The cost of doing business (the high price of real estate, manning call centers for a separate time zone and relying on people from Manhattan or Charlotte knowing how to pronounce simple street names like Ano’ilei Place, and the cost of shipping equipment like ATM machines) apparently isn’t worth it for large banks, especially since Hawaii is a relatively small market. This doesn’t really affect people who live in Hawaii — they remain fiercely loyal to local banks like First Hawaiian and Bank of Hawaii ($2.6 billion) — but it does affect tourists who may not being able to withdraw money from an ATM without paying exorbitant fees. An example of “too small to fail”?
In job news, Kinecta Federal Credit Union currently has openings for two roles: Director of Hedging, and Secondary Marketing Manager, both in its Manhattan Beach, California headquarters. The Director of Hedging will be responsible for interest rate risk management of the mortgage pipeline & inventory available for sale and will be accountable for hedging analysis and recommendations. The Secondary Marketing Manager will support the organization in all facets of pricing, pipeline management and delivery including mortgage-backed securities. Each of these roles requires a minimum of 5 years of proven experience in the related field. If you are interested in joining the team, please send your confidential questions and resume to Sylvia LeNoir at Sylvia.email@example.com and visit http://www.kinecta.org/ to learn more about the company.
Caliber Home Loans is expanding its Software Development team and is looking for experienced .NET and Business Intelligence Developers. With the numerous regulatory changes that have occurred in recent years, technology has never been more important within the mortgage industry. Caliber employs a veteran team of mortgage banking technologists to enhance and maintain its systems. Caliber originates home loans through a network of over 100 retail branches, wholesale lending, correspondent lending, mini-correspondent lending, and a consumer direct centralized operational center. To learn more about Caliber and their IT opportunities, please visit the website at www.caliberhomeloans.com or you can send your resume or questions to Leslie Donatien at firstname.lastname@example.org.
And Freedom Mortgage is expanding in Texas. “Everyone knows ‘to do business in Texas you need to be from Texas’ and that’s why Freedom Mortgage has developed a ‘TEXAS TEAM’ to work with Brokers and Mini Correspondents in the State. The new ‘Texas Team’ will be made up of AEs, junior underwriters, and underwriters right from the Heart of Texas. Who better to understand the market and provide the upgraded customer service?” This new Team went into effect on April 14th and is looking forward to providing high levels of customer service to match up with Freedom’s strong pricing and expansive products. In addition, Freedom is looking to add AEs in the Houston and Austin markets who want to grow business for a strong long term lender. For more information about the “Texas Team” or AE opportunities you can contact Don DiLucchio, Regional Manager, at email@example.com.
From jobs to old people…I don’t know much about Social Security, other than it seems the reports of its death, or that it was supposed to run out of money ten years ago, were greatly exaggerated. LOs have to deal with it all the time and the Mortgage Bankers Association of the Carolinas sent out this note from a Public Affairs Specialist at the Social Security Administration: “In December, many were told about some upcoming changes to the services we provide at Social Security offices across the country. Based on feedback we received from many of our stakeholders, we decided to delay the implementation of these changes to later in the year. Beginning August 2014, we will no longer issue Social Security number printouts in our field offices. Individuals who need proof of their Social Security number and cannot find their card will need to apply for a replacement card. In addition, beginning October 2014, our field offices will stop providing benefit verification letters, except in emergency situations. Benefit verifications are available online, and can be obtained anytime by registering for a ‘my Social Security account’ located at: www.socialsecurity.gov/myaccount, or requested through our national toll-free number: 1(800)772-1213. To assist your outreach activities, we developed and updated outreach materials on our third party page at: http://www.socialsecurity.gov/thirdparty/whatsnew.html.”
Huh? The purchase market is now 60% of the business that flows through Ellie Mae? Yup: “Get the New Ellie Mae Origination Insight Report. Purchase mortgages continued their momentum in March, climbing to 60% of closed loans. But what about other critical data? Time to close? DTI? FICO scores?” Here you go: http://www.elliemae.com/origination-insight-reports/EMOriginationInsightReportMarch2014.pdf?elq=d6fee0397e78466397f48035dd827824&elqCampaignId=1627.
Here’s a good question: can a lender who emails disclosures to loan applicants via an e-delivery system, still remain compliant under RESPA and TILA, if one co-borrower consents to electronic delivery, but one does not? With respect to TILA disclosures, generally, when there are multiple applicants, the disclosures may be made to any applicant “who is primarily liable on the obligation”. However, when there is a right to rescind, the disclosures “shall be made to each consumer who has the right to rescind”. So, if the transaction is a refinance, all applicants must consent to the e-delivery in order for the lender to be in compliance. Regarding RESPA disclosures, Reg X (the implementing regulation of RESPA) simply states that “the lender must provide the applicant with a GFE”. However, the definition of “applicant” is not clearly defined, so the safe approach would be to give the GFE to each applicant, which under an e-delivery system would require each applicant to consent to e-delivery.
I recently received an email inquiring about the new appraisal rules; specifically, when, and what version, a borrower needs to be provided with in order to remain compliant. As a reminder, under ECOA Valuation Rule, loan applications received on or after January 18, 2014, a creditor must provide an applicant with a copy of the appraisal and other written valuations “upon completion, or three business days prior to consummation of the transaction, whichever is earlier”. The originator does not need to provide the borrower ALL versions of the appraisal, only a copy of the LATEST version. However, if the borrower receives a copy of an appraisal, or written valuation, which is then revised, a copy of the updated version must be sent.
And while I am yammering about compliance – it becomes more important for lenders every week – audits are the minds of almost every person I come in contact with, so it was with no surprise that I was recently asked about post-closing quality control audits, and when they must be completed. HUD mandates that FHA and VA loans be reviewed no more than 90 days from closing. In Freddie Mac’s Single Family Seller/Servicer Guide, the results of quality control reviews must be reported in writing to the Sellers’ senior management within 90 days of selection of the mortgage files for review. Fannie Mae requires that the entire post closing quality process be completed within 120 days from the month of loan closing; as it has been explained to me, with the following breakdown: Loans must be selected for audit within 30 days, the quality control review and rebuttal must be completed within 60 days, and the results of the audits must be reported to senior management within 30 days.
There is a lot going on with lenders – some of it very interesting – let’s play some catch up!
A few weeks back I mentioned that ResMac, based in Boca Raton, Fla had launched a new Wholesale Division. Well, this week management is launching their “747 Alt Doc Portfolio ” program. This offering is now available for ResMac brokers to offer to their customers, referral sources, realtors and prospects. Loan sizes range from $250K to $2.5M and contain such features as: 620 minimum FICO, no limit on cash out (including investor properties), no seasoning requirements and income verification options including bank statements, P&L and no 4506T. All rates are 5/1 ARMS and offer both fully amortizing and I/O options. For more information about this product, and/ or to become an approved broker, contact ResMac’s Production Support Team at www.resmacwholesale.com and start with “B2B Overview”.
TD Bank made the airwaves with its new high LTV, no MI program: http://www.marketwatch.com/story/td-bank-eliminates-private-mortgage-insurance-with-updated-right-step-mortgage-program-2014-04-21?reflink=MW_news_stmp. I believe that TD keeps everything in its portfolio…
NMI Holdings Inc. announced that National MI’s application for an insurance license in Wyoming has been approved by the Wyoming Department of Insurance. With Wyoming’s approval, National MI is now licensed to write mortgage guaranty insurance in all 50 U.S. states and the District of Columbia.
In conjunction with imortgage, National MI has launched a new lender-paid mortgage insurance program that introduces a delegated assurance review process to offer lenders underwriting protection from the very beginning of the transaction. The program also provides rescission relief for every insured loan where the borrower has made timely payments for the first 12 months.
First Community Mortgage is offering a new FHLMC Super Conforming product through its wholesale channel, which is available for 10-, 15-, 20-, and 30-year terms. FCM has also raised the maximum LTV for Conforming purchases of investment properties from 80% to 85%, removed the requirement for a 24-month rental history for cash-out investment property transactions, and added a 2/2/5 cap structure option for its Non-Conforming 5/1 ARMs. In addition, the No Lender Admin Fee is now being determined based on the total loan amount, and Conforming 3/1 ARMs are no longer available to lock.
MGIC has published its new Fannie and Freddie-approved master Policy, which offers upgraded Gold Cert coverage that includes 36-month rescission relief for all loans and the ability to upgrade to 12-month rescission relief for borrower misrepresentation, underwriting errors, and property valuation variances. Under the new policy, lenders also have several options for loan submission, including submitting data only files either via the Loan Center or their own LOS, submitting key documents for an MGIC MI Underwrite, or submitting a fully documented loan for a Full-Doc Requirement Underwrite. The policy goes into effect for all loans submitted on or after July 1st.
In training and events news:
AllRegs is offering an online training program on ATR and QM designed to foster a comprehensive understanding by covering background, key terms, applicability, exemptions, recordkeeping, underwriting, and third-party documents. The course is self-paced and can be completed through an online exam within 12 months of the initial registration date. For more information, refer to http://solutions.allregs.com/content/courses/ability-to-repay-and-qm.html?utm_campaign=AllRegs-Advisor-February%202014.html&utm_medium=email&utm_source=Eloqua.
The FDIC sponsors and participates in various conferences and events. The list of events has been updated. Visit: http://fdic.gov/news/conferences/.
In Northern California, East Bay CAMP has its annual trade show on April 30th. To learn more about the event, including its Mortgage marketplace (mini trade show), registration, and sponsorship, visit the registration link at: https://events.r20.constantcontact.com/register/eventReg?oeidk=a07e91q0kkh23c953ad&c=f2ac7170-328a-11e3-92e0-d4ae52986b44&ch=dfb1f670-ad83-11e3-b076-d4ae52710c75.
IMF announced its new webinar: Non-QM Opportunities: Lending Outside the Qualified Mortgage Box on May 8. “…the advent of tough new ability-to-repay/qualified mortgage regulations has prompted more than a few mortgage market players to consider non-QM lending in the months ahead. Some are eyeing the non-QM opportunities in the jumbo market while others are eyeing potential non-QM profits in the nonprime space. Does non-QM lending make business sense for your company? What are the legal risks in this new mortgage market sector? Get the answers to these and many other questions on May 8 when Inside Mortgage Finance presents a must-attend webinar on Non-QM Opportunities: Lending Outside the Qualified Mortgage Box. Hear from a panel of experts on how you can tap into the non-QM lending niche without putting your business at risk.”
All of these changes are much more exciting than the markets, especially when there is very little news here in the U.S. Speaking of which, the index of U.S. leading indicators increased in March by the most in four months, a sign the economic expansion will strengthen following harsh winter weather. The Conference Board’s index, a gauge of the outlook for the next three to six months, rose 0.8 percent after a 0.5 percent gain in February, slightly higher than expected. Today we’ll see Existing Home Sales and more earnings from companies. But rates barely budged yesterday, and the yield on the 10-yr T-Note closed at 2.72% – right where we began the day and where we were Thursday afternoon. In the very early going today we’re at 2.70% and we can expect agency MBS prices to be a shade better.
I’m a guy. I even used to change the oil on my ’66 Mustang. But not anymore, and this humorous, albeit slightly long, article explains why guys don’t know how to do anything anymore, not even flush toilets: http://online.wsj.com/news/articles/SB10001424052702304675504579391143240721978?KEYWORDS=manliness&mg=reno64-wsj&url=http%3A%2F%2Fonline.wsj.com%2Farticle%2FSB10001424052702304675504579391143240721978.html%3FKEYWORDS%3Dmanliness.
( Copyright 2014 Chrisman LLC. All rights reserved. Occasional paid job listings do appear. This report or any portion hereof may not be reprinted, sold or redistributed without the written consent of Rob Chrisman.)