Dec. 4: Secondary, LO, AE jobs; broker, anti-fraud, marketing tools; compliance news: what is EGRRCPA?

Politics seems to be in the news as never before. And we still have eleven months until the presidential election! I already have LOs writing to ask about how different outcomes may impact their business. STRATMOR has a piece titled, “Politics do Indeed Impact Interest Rates and Borrowers”. Everything is debatable, right? I imagine that even the taste of today’s pot-related joke, at the bottom, is debatable. How about whether or not cannabis-related income can be used to qualify for a home loan? The FDIC announced regulatory changes, not dealing with income, but clarifying the legal status of hemp growth and production and the relevant requirements under the Bank Secrecy Act. More on this and compliance notes below!


A large mortgage lender is looking to fill Secondary Marketing and Lock Desk positions in the Chicago area to support the company’s growth. Management and analyst level positions are available, and are located in the Chicago suburbs. The lender has a strong focus on purchase business and is dedicated to providing the highest level of customer service and support. For more information or to submit resumes, please contact Chrisman LLC’s Anjelica Nixt.

“In today’s rapidly changing workplace, it’s important to be a continual learner, build critical skills and seek experiences that will add value to your professional career. At Citizen’s Bank, we invest in our colleagues learning and career development. We host Development Weeks: Two-weeks of dedicated sessions that provide focused opportunities for colleagues to build critical skills for today and tomorrow at all levels of the organization. If that sounds like a company you want to build your future with, apply to Citizens Bank today. For questions, please email Home Mortgage Recruiting.”

Is it time for something new? Make 2020 the year where you make a bigger impact and are rewarded for it! String Real Estate Information Services is hiring Senior Account Executives! String, a wholly owned subsidiary of SitusAMC, is the industry-leading title services provider. Building on 6 years of significant growth, String seeks to expand its client-facing team. Are you experienced working with title agents? Are you passionate about helping your clients reduce costs, operate more efficiently, eliminate operating risks and take advantage of volume spikes? As a String Account Executive, you will leverage String’s dedicated title process experts (3,000+) to provide tech-enabled search, production and curative title services. CLICK HERE for the full job description or send your resume to String Managing Director, Prashant Kothari.

Lender services and products

In order to meet modern consumer expectation, speed is key. Stearns Wholesale recognizes the importance of a fast, customized experience to serve more borrowers effectively and keep your referral partners euphoric. In a recent release, the new Accelerator program was introduced. Streamlining the process and improving the price on popular scenarios with the same best-in-class fulfillment was the driving force behind this development. There is no minimum loan amount, no minimum credit score, just requiring the borrower is a W2 wage earner that owns no other REOs and has no recent major derogatory marks. Better value, faster, sustainable. Click HERE to learn more about this program or connect with a Stearns Account Executive.

Join National Mortgage Professional Magazine for a DealDesk webinar on Bank Statement Programs, being held on Thursday, December 5 at 2 pm ET / 11 am PT. This webinar will be focused on Angel Oak’s most utilized Bank Statement program, which is ideal for self-employed borrowers. Self-employed borrowers have a challenge when it comes to qualifying for a mortgage due to tax write-offs. This program’s focus is on business owners whose personal tax returns may not be reflective of their ability to repay a mortgage obligation. Bank statement loans allow for these borrowers to close. Tax returns are not required and borrowers no longer have to own 100% of a business. We invite you to register for the webinar and submit your DealDesk scenarios right here.

2019 continues to be a breakthrough year for QLMS.  In just 11 short months, the powerful QLMS partner base doubled from slightly more than 3,000 partners at the beginning of the year to 6,200 approved partners today – a whopping 5,800 of which are independent mortgage brokers.  The explosive growth will continue in 2020 as QLMS will expand the partner base to 10,000 and beyond.  This incredible growth only happens if brokers see them provide continuous and intense value.  After all, a broker’s superpower is choice.  QLMS’ goal is to be the obvious choice each day and they take that mission seriously.  If you’d like QLMS to earn your business, click here and grow stronger together.

FundingShield reminds lenders that the holiday season brings increased wire / closing / title fraud as per the trends found in its data on the $560 Billion+ in closings it has protected via the industry’s most trusted MISMO Certified data-set of live & verified accounts. “Lenders should take proactive and preemptive steps to safeguard against these operational risks that are heightened due to holiday scheduling, employee vacations and rushed closings to meet year end deadlines,” shared Ike Suri, Chairman & CEO. For a few dollars a loan Fundingshield will protect closing proceeds to confirm funds are going to the intended recipient, verify good standing of closing agents, check licensing & backgrounds and confirm the title insurer’s acceptance of risk on each closing.  Services are accessible via easy to integrate APIs as well as by Encompass by Ellie Mae. Consumer down payment wire fraud protection is also available for lenders via B2B and B2B2C preferred partner integrations. Contact

Over the next decade, Zillow is predicting nearly a million homes will be released into the market annually by people aged 60 or older. This “Silver Tsunami” won’t hit us all at the same time or with the same force, but you can be sure that lenders like Bank of England Mortgage, Alterra Home Loans, Prime Lending, Eustis Mortgage, RWM Home Loans, and Premier Lending, Inc. will be riding those waves right to the closing table. What’s their secret? They’ve realized what over 70 other lenders have already discovered: in a world where timing is everything, Sales Boomerang’s Automated Borrower Retention System puts you in the right place at the best time. Schedule a demo today and catch the wave.

‘Tis the season for consumption and ultimately credit card debt. As the purchase and rate/term refinance applications slow down this time of the year, it is an excellent time to remind your clients that a cash-out refinance can help them start 2020 with better habits and cashflow. Americans don’t just need the cash; they also need your counseling on what to do to improve their FICO scores and stop the habits that could lead to racking up debt. Your expertise and work can be life changing. As you discover clients that need higher LTV’s than your conforming lenders can offer, remember that Deephaven Mortgage has cash out options up to 85% and debt consolidation to 95% LTV. Use our scenario calculator, AUS, and AE’s to determine if a Non-QM loan gets them to their goals! Get in touch today by contacting us at (Wholesale) or (Correspondent).

Comply, or else!

Greetings from Southern California and the California MBA’s Legal Issues and Regulatory Compliance Conference. It is well attended, given that many of the legal trends seen here impact courts and lenders around the nation. How about Lusnak v. Bank of America, No. 14-56755, dealing with the requirement of financial institutions to pay borrowers at least 2 percent annual interest on funds held in the borrowers’ escrow accounts? (Yes, it is similar to escrow cases filed in New York.)

How about the definition of an automatic telephone dialing system (ACA International v. FCC)? Can you be sued for dialing a wrong number or is there a safe harbor? In a data breach, can you be sued by someone involved in the breach who doesn’t suffer any damages? (Remember that starting 1/1 CCPA creates an avenue to recover statutory damages for California residents who have had their data breached.) And are you following Seila Law v. CFPB?

Ever heard of EGRRCPA? It deals with QM loans for small institutions. PACE loans are included in that, as are HMDA and escrow requirements for small lenders. And don’t forget the 2019 Taxpayer First Act! Better have that additional paperwork in the loan file if you’re going to sell that loan.

For example, in a recent Announcement, Lakeview Correspondent issued information on upcoming Taxpayer Consent Form Requirement and the SAFE Act Regulations amendments in effective as of November 24th.

Don’t forget that on 10/28 HUD and DOJ announced a Memorandum of Understanding (MOU) regarding violations of FHA requirements, triple damages, potential FCA violations, and so on. Will the big banks come back to FHA lending? Stay tuned! And Ginnie Mae issued its servicer rating requirements, and new issuer information in the form of APM 19-06.

Fannie Mae, Freddie Mac, and the Federal Housing Finance Agency discussed a proposed timeline, presented by the MBA, for the implementation of the new Uniform Residential Loan Application (URLA). The new timeline is a result of changes to the URLA that were announced in August, which include eliminating the language preference question. The proposed schedule includes mandatory use of the new form by November 1, 2020. Early adoption can begin on August 1, 2020. Lenders that coordinate with the GSEs and complete a readiness questionnaire may be permitted to use the new form beginning May 1, 2020.

Pot stocks are off their highs due to the slow pace of legalization. But in the U.S., there is movement. The Federal Reserve Board, the Federal Deposit Insurance Corporation, FinCEN, the Office of the Comptroller of the Currency, and the Conference of State Bank Supervisors in conjunction with the state bank regulators issued a statement clarifying the legal status of hemp growth and production and the relevant requirements under the Bank Secrecy Act (BSA) for banks providing services to hemp-related businesses. Banks are no longer required to file suspicious activity reports (SAR) for customers solely because they are engaged in the growth or cultivation of hemp in accordance with applicable laws and regulations. For hemp-related customers, banks are expected to follow standard SAR procedures, and file a SAR if indicia of suspicious activity warrants.

Capital markets

In recent weeks and months the markets remain focused on the health of the consumer, especially now that the holiday shopping season has officially kicked off. Overall, positive data persists although there are a few indications that the pace of consumer spending may begin to moderate. Consumer confidence eased for the fourth straight month, but remains at a high level with the record setting stock market and low gasoline prices providing support for spending growth. Spending grew at an annualized rate of 2.5 percent over the last three months which and is expected to hold up throughout the remainder of the fourth quarter. Over on the production side of the economy, durable goods orders’ unexpected increased in October and core capital goods shipments also increased. This could be a sign that manufacturing activity might be stabilizing after months of contraction. The recent data has done little to alter the outlook that GDP growth will continue to moderate in the fourth quarter as consumer spending growth eases and manufacturing muddles through in the face of trade tensions and slowing global growth.

Turning to rates, U.S. Treasuries & MBS rallied sharply yesterday, reversing course from the start of the week amid renewed trade war worries. President Trump is now moving towards waging trade wars on multiple fronts, after he threatened heavy tariffs of up to 100 percent on French goods such as cheese, champagne, cosmetics and other products. The U.S. says it is retaliation for France’s new digital services tax on technology companies. French Finance Minister Maire promised a “strong” EU response.

This comes after President Trump threatened to reinstate tariffs on steel and aluminum imports from Brazil and Argentina on Monday. Additionally, President Trump said during an early-morning press conference from the NATO summit in London that he likes the idea of waiting until after the 2020 election to sign a trade deal with China. He closed saying that no deal was better than a bad deal and that yesterday’s sell-off in equities was “peanuts” versus the importance of a good deal. Remember, the next round of tariffs on Chinese goods are scheduled to kick in on December 15 of this year. Commerce Secretary Ross confirmed that no high-level talks are currently scheduled between the U.S. and China prior to that date. Stocks dropped around the world, bonds rallied, and the 10-year Treasury yield closed the day -13 bps to 1.71 percent.


Today’s calendar kicked off with the Weekly MBA Mortgage Index for the week ending November 29, which showed applications decreased 9.2 percent from one week earlier. The results include an adjustment for the Thanksgiving holiday, but are still likely to be distorted to some extent by the Thanksgiving Day holiday. We’ve also had the November ADP Employment Change (67k).


Later this morning will be the final Markit Services PMI for November, and the November ISM Non-Manufacturing Index. The NY Fed will conduct an MBS purchase operation between 11:15 and 11:45am in GNII 3.0 percent ($504 million) and 3.5 percent ($182 million). We begin the day with Agency MBS prices down .125 and the 10-year yielding 1.73 percent, a bit of a bounce back from yesterday on no real news.

I used to smoke weed and go to the class.

I’d sneak in ten minutes late with a BS excuse.

Slink down low at my desk.

Pray to God nobody asked me any questions.

I was the best teacher ever.

Visit for more information on our industry partners, access archived commentaries, or to subscribe to the Daily Mortgage News and Commentary. If you’re interested, visit my periodic blog at the STRATMOR Group web site. The current blog is, “Politics do Indeed Impact Interest Rates and Borrowers” If you have the inclination, make a comment on what I have written, or on other comments so that folks can learn what’s going on out there from the other readers.


(Market data provided in partnership with MBS Live. For free job postings and to view candidate resumes visit LenderNews. Currently there are hundreds of mortgage professionals looking for operations, secondary and management roles. For up-to-date mortgage news visit Mortgage News Daily. For archived commentaries, or to subscribe, go to Copyright 2019 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.)

Rob Chrisman