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May 6, 2012: Lender, conference, and investor updates; the conversations at the MBA Secondary conference
Rob Chrisman
Here
in the borough of Manhattan the 1.6 million residents are abuzz
with the thought of the MBA’s
National Secondary conference being in town. Like other
MBA events, it promises to be well attended, with the hot buttons being the
CFPB (“They won’t audit someone my size, will they?”), QM
(“There won’t be a secondary market for non-QM loans, so I hope
the scope is broad with clear definitions”), new products (“New
products? Heck no – our best products are our people and our
process!”), compliance (“Do you know how many audits we go
through every year? And they aren’t cheap!”), HARP 2.0 (“We’re
still looking at the risk – and what warehouse banks are
accepting them?”), investors (“What do you hear about the Wall
Street firms getting back in, Redwood Trust or PennyMac?”),
Fannie & Freddie & Ginnie (“What’s the latest on
approval times?”), and servicing (“I’d rather own it than give
it away! But how am I going to finance it?”).
What
is missing, of course, is any substantive talk about
rates…they’re fine.
In
what some believe are second only to the “Sunday Funny Papers,”
as my Dad who sold newspapers during the 1930’s calls the
comics, how about some
somewhat recent
lender/investor/agency/MI updates, and conference/training
updates? As always, it is best to read the actual
bulletin, but this will give one a flavor for what is happening
out there. In no particular order…
Owing
to the high volume of emails with post purchase document
attachments Affiliated
Mortgage has been receiving, it is asking correspondents
to send such emails to postpurchasedocs@affiliatedcorrespondent.com.
All loans delivered to AMC on May 7th or after that were closed
with Power of Attorney will require a “Certified True Copy”
confirming that the loan is a copy of the original. The name of
the company and the signature of the individual doing the
certifying must be included as well. Lastly, AMC’s Settlement
Agent List Exhibit 5-01 has been revised to include additional
agents that are not eligible to close transactions that will be
delivered to AMC. The full list is available at: http://www.affiliatedcorrespondent.com/wc/content/exhibits/5-01_Settlement_Agent_list.pdf.
On
May 15th Wells Fargo
Funding will be presenting a webinar on VA basics that
will cover LTV ratios, purchase and refinance programs, and
borrower eligibility. Attendees will also have the opportunity
to speak with a member of the Wells Funding Diverse Segments
team about strategic positioning with the VA in their markets.
Registration will be available at www.wfhmevents.com until
Friday, May 11th; the access code is VA 101.
Wells
Fargo
has corrected its communication on the Mortgage Electronic
Registration System® (MERS) updates it published on February
13th. The memo wasn’t meant to imply that February 27, 2012 was
the date on which compliance was required with the MERS Release
21.0 requirements—this date is when the changes were in effect
in the system. Wells has offered further clarification on the
requirement that sellers are required to initiate the Transfer
of Beneficial/Transfer of Servicing Rights (TOB and TOS,
respectively); TOB here is defined as the date on which Wells
purchased the loan, and TOS is the first payment due.
Clarification has also been provided on the timing of final
document delivery and Mortgage Identification Numbers, a full
table of which is available from regional Wells sales teams. If
the final documents are delivered prematurely, they run the risk
of failing to transfer or not being matched to a Wells Fargo
Funding-owned asset, and being returned to the Seller.
Wells has revised its rate sheets in accordance with Fannie’s
updates to the Desktop Underwriter Refi Plus Program. This is
effective for Best Effort Registrations and Best Efforts locks
on and after April 28th and Mandatory Commitments on and after
April 23rd.
A couple of reminders for Wells sellers: a copy of the most
recent version of the completed Notice to HomePath Property
Buyers Regarding Appraisals publication should be included in
all closed loan packages and dated by the buyer, and all
mortgages sold to Wells must be valid, existing, and enforceable
first liens on the mortgaged property. Recent rulings in Texas
may affect the latter, as Texas properties with an agricultural
exemption must comply with the Texas Department of Insurance’s
Title Insurance Basic Manual, and properties may be affected by
rollback taxes if they are no longer used for agricultural
purposes, thereby compromising first lien position.
Wells Fargo Funding now accepts life-of-loan policies from AFR
Services, provided that the loans include a flood zone
determination with life-of-loan service (a Third Party Flood
Certificate) indicating if the property is in a Special Flood
Hazard Area. Sellers can procure a Third Party Flood
Certificate from CoreLogic, Elite Lender Services, LPS National
Flood, Wells Fargo Flood Service, or American Flood Research,
Inc., all of which are approved by Wells, or have Wells net fund
the loan $19 to do so. A Third Party Flood Certificate can be
obtained from any FEMA-approved vendor, but the loan will be net
funded $19 regardless if the vendor is not one of those
mentioned above.
To better reflect current wire authorization requirements, Wells
has revised the Wire Authorization and Certification Form (Form
8).
Previously Flagstar
announced that it would suspend the Freddie Mac Open Access
Program, Freddie Mac Open Access II. For table-funded
transactions, loans must be funded and delivered by June 1,
2012, while loans for correspondent transactions must be closed
and delivered by June 8, 2012. Flagstar will continue to accept
new registrations provided that submission, lock, and funding
meet these deadlines.
Flagstar
alerts
clients of a glitch in the execution section of the online
broker-correspondent agreement. There is an error in the
sections that ask for the customer and principal officer’s
names; the customer’s name should actually be listed as
“Seller,” and the “By” field is where the principal officer
should sign. The glitch should be fixed soon, but for now the
principal officer should sign the agreement in the “Seller”
field.
Effective
for
all Flagstar-serviced HARP loans locked on or after April 6,
2012, the three Expanded Approval Risk Class price adjustments
will be consolidated into a single price adjustment. The new
adjustment for EA Risk Classes 1-3 is now -0.250.
Flagstar
has
indefinitely suspended the Freddie Mac Open Access program
Freddie Mac Open Access II, and any loans in the pipeline
currently registered under the program will need to be locked
and submitted to Underwriting on or before April 27th. These
should be funded and delivered before June 1, 2012.
Flagstar reminds sponsored originators that they are not
permitted to close loans in their own name without being
approved by the FHA. These loans must close in Flagstar’s name;
loans from unconditionally approved lenders that are
underwritten by the correspondent must close in the
correspondent’s name. Loans from lenders who are still in the
FHA test case phase must be closed in the correspondent’s name
as well. In addition, non-approved lenders are required to be
sponsored by at least one lender with FHA approval whom they
have registered as a third party originator in the FHA
Connection.
In light of California Senate Bill 183, which requires all
existing homes “intended for human occupancy that have a fossil
fuel burning appliance, fireplace or attached garage” to feature
a carbon monoxide device, the FHA requires installation of such
a device where an appraiser finds it absent. Flagstar will not
clear FHA loans to close until an inspection proves that the
installation has been completed. Fannie Mae Form 1004D competed
by an FHA-approved appraiser, HUD Form 92051, or a paid invoice
from a licensed carbon monoxide device professional are all
acceptable forms of proof.
The Flagstar Conventional Underwriting Guidelines manual now
includes revisions to guidance on condos, document expiration
dates, and non-permanent resident aliens.
Flagstar has added Essent
Guaranty to its Loantrac system; Essent can now be
selected as the Mortgage Insurance provider when underwriting MI
loans.
Following the tornado activity in Iowa, Kansas, and Oklahoma,
Flagstar (and other investors) is requiring that properties in
particular cities be re-inspected and deemed in satisfactory
condition. The re-inspection should indicate that the property
hasn’t sustained any flooding and/or windstorm damage, provide a
statement on the neighborhood conditions, and include a photo,
and standard FHA and VA regulations apply to relevant
properties. This affects properties in Creston and Thurmon, IA;
Rush Center, Solomon, and Wichita, KS; and Norman and Woodward,
OK.
As
per the “Automated Underwriting Section” of the Fifth Third Correspondent
Seller Guide and Product Manual that refers to the validation of
AUS findings, the correspondent seller is required to submit the
most current LP or DU findings that reflect the terms as approve
and closed. The information on the DU and LP assignment screens
serves as sufficient verification and should be included in the
loan closing package. And a 0.25 adjuster will be subtracted
from the price on all HARP II products (HASP—Open Access and DU
Refi Plus) that lock on or after April 16th.
Fifth Third reminds clients that the Broker Cert., listed prior
to the underwriting form on the loan submission checklist, can
be found on the Wholesale Connect task center page. Clients are
also reminded that any condominium documents submitted should be
fully completed and sent to wholesale.newsubmission@53.com
(documents included in a new submission file) or wholesale.underwriting@53.com
(documents emailed as a condition).
The FHA’s Basic Loss
Mitigation training seminar series will include a session
in Atlanta on May 11th. This is aimed at HUD-approved housing
counseling agencies, local servicing lenders, and nonprofits.
To register see https://eclass.hudtulsa.org/.
This
training will be available in Jacksonville, FL on May 23rd as
well. The National Servicing Center is also offering free loss
mitigation training for HUD-approved mortgagees, HUD-approved
housing counselors, and nonprofit housing counselors in Oklahoma
City on May 16th and 17th and August 15th and 16th. To register
for the Oklahoma City training, see http://portal.hud.gov/hudportal/HUD?src/program_offices/housing/sfh/nsc/training.
The National Reverse
Mortgage Lenders Association will be holding its Western
Regional Meeting in Irvine, CA on May 16th and 17th. More
information is available at http://www.nrmlaonline.org/.
FHA-HUD
provides
online training for HOPE LoanPort Users every Tuesday and
Thursday, registration for which is available at
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