Jan. 16: AE, LO, FHA jobs; QC automation, broker products; disaster news; regulatory & legal bits for lenders; a good video joke
How are we halfway through with January already? Wasn’t it just Christmas Day? Happy Martin Luther King Day (in Alabama and Mississippi, Robert E. Lee Day): no loans funding but many lenders and vendors are open. Time flies, and with the slowdown in business originators have plenty of time to actually look for business. STRATMOR’s Sue Woodard suggests, “Every LO out there should do this once a day: call a refi customer from last year, check in, and congratulate them on their low rate. Prospecting is a numbers game, and LOs may be surprised at the referrals received. I heard a success story last week on this strategy: two purchase transactions within ten calls!” What we are no longer surprised by is the ceaseless Washington DC quagmire. This week’s drama: the Treasury Department warned the U.S. will reach the debt limit on January 19 and will need extraordinary measures from Congress to avoid a default. (If your home is being flooded, do you figure out how to stop or drain the water, or do you raise the roof?) And while I’m on the subject of big numbers, I recently received this note from a successful loan officer. “Rob, my commissions in 2020 and 2021 were over $500k each year. In 2022 they dropped to about $200k. Are you seeing this everywhere?” Yes, I am. But keep things in perspective. In the U.S., and certainly in the world, $200k puts you into top percentile. (Although there is none today due to the holiday, this week’s podcast is sponsored by Candor. Candor’s patented automated underwriting decision engine, CogniTech™, is a state-of-the-art, 100% machine platform that can handle infinite loan scenarios.)
Employment and transitions
“An IMB is seeking experienced Loan Officers who want to take things to another level. We are searching for 1 person in 9 states. LO must have lifetime production greater than $100m, and reside in KY IN, MI, NC, SC, TN, GA, TX, or CO. Candidate must have strong leadership skills and have a desire to oversee the growth in their state. Our goal is to grow with the right people in the next stage. This position will earn bps on every loan closed in the state they manage (in addition to their own production). This is truly a position with unlimited upside based on the efforts of the candidate. The ideal candidate would have a large circle of influence in the state and be able to grow new talent within each state. We are also hiring in all the above states for Loan Officers not wanting to manage or without the lifetime production above. Send your confidential resume to Chrisman LLC’s Anjelica Nixt for forwarding.”
“According to Apollo Technology, 60% of employees believe that their coworkers are the biggest contributor to their happiness at work. 74% of employees in the US believe that company culture is one of the biggest contributing factors to job satisfaction. At Churchill Mortgage, people are our top priority. We believe finding talented people who align with our culture is a crucial part of the health and success of our company. Are you looking to find a workplace with talented co-workers and leadership who will help you continue to grow? Do you want to work somewhere where you are valued? We are expanding, largely due to our culture and our ESOP, which means that our employees are owners, laser-focused on the success of our company & the satisfaction of our customers. Don’t take our word for it! Hear from some of our latest team members on why they chose Churchill: Kisha Weir, Andrew Wagner, Dean Sargent & Kelly Lee, Churchill’s new SVP, National Production!”
“Mega Capital turns 25 years old in 2023. Mega Capital is proud of our diverse line up of products from Conv, Government and Non-QM. Our proprietary MGenius system allows the broker to run a Non-QM AUS on our portal, just like a conventional loan, and receive findings. Mega Capital is continuing to grow our team, having just added a group of 14 AEs and a RSM that we are excited about and are looking for more sales talent in many states that are available. If you are interested in joining the team, contact Ed Darrow, National Sales Manager 818 657 2600 X 340.”
The FHA has one vacancy for Director, Home Mortgage Insurance Division in multiple locations. Candidates will be FHA selected for a job assigned to one of the official duty stations listed in announcement 23-HUD-403-P. Job functions include formulating new policies and procedures, develop or direct development of the credit underwriting standards for home mortgages, creating major policy initiatives, mortgagee letters, and processing directives.
Lender and broker software, products, & services
Orion Lending is proud to announce the release of its 0/1 and 2/1 BUYDOWNS on FHA, VA, USDA, and Conventional products! Make yourself an expert by joining one of our in-depth product training sessions, visit here to sign up! Make sure to check out the matrix and pricing today! Orion offers industry leading STAR Portal technology for easy submissions and a 24-hour UW Purchase Commitment too! New Brokers can receive Express Approved, meaning you can start submitting loans by the end of the day and New Brokers receive a 15 BPS Price Special** on all products! Click here to get approved with Orion!
Your 2023 Mortgage Horoscope: In recent months, market risks threw shade on past years of success. This doesn’t have to be the case in 2023. Remember the song “Man in the Mirror”? The planets are suggesting that now is the time to ask that man or woman to make a change. It’s time to put aside those redundant, manual QC processes and let AuditGenius, Indecomm’s loan QC automation and SaaS technology, do more. Put your trust in a proven and tested QC system that audits an average of 800,000 loans a year and delivers unlimited potential for your QC audits! The stars (and Indecomm) wish you to spend your free time on high-value mortgage tasks while reducing QC expenses. With AuditGenius, you will spend less time creating and answering checklists, validating data, and fighting with excel. Reach out to Linda Bomar to realize your future in Quality Control!
FEMA calls the shots when it comes to disaster declarations. And when FEMA publishes them, lender and investor policies and procedures are triggered. And with the United States stretching from Maine through California, out to Hawai’i, and up to Alaska, we can be guaranteed something is going on somewhere, sometime.
FEMA issued a disaster declaration, DR-4680-FL on December 13, 2022 to include Florida counties of Brevard, Flagler, Lake, Putnam, St. Johns, Volusia for incident period November 7th – November 30th.For all loans that have not yet closed but have an existing appraisal, follow Newrez Wholesale disaster inspection steps.
AmeriHome spread the word that on 1/14/2023, with DR-4683, FEMA declared federal disaster aid with individual assistance has been made available to California counties affected by severe winter storms, flooding, landslides, and mudslides from 12/27/2022, and continuing.
On 1/15/2023, FEMA DR-4684-AL declared federal disaster aid with individual assistance available to 2 Alabama counties, Autauga and Dallas affected by severe storms, straight-line winds, and tornadoes on 1/12/2023. View AmeriHome Mortgage’s Disaster Announcement 20230104-CL for inspection requirements.
Regulatory and legal snapshot
Most news attention about the federal government the last week focused on mishandled classified documents, but federal agencies other than the Justice Department have been busy in the new year with a couple proposed rules that directly impact mortgage companies and their employees. On those topics, I got a heads-up from attorney Brian Levy that he’s annoyed (again) by the government and to expect another one of his Mortgage Musings tomorrow morning about the recent FTC proposed rule seeking to ban non-compete clauses and the CFPB’s proposed rule demanding financial services companies identify and submit form contracts to a CFPB registry regarding consumer waivers of rights. View past editions and obtain a free subscription to Levy’s Mortgage Musings to get tomorrow’s Musing e-mailed by signing up here.
From my perspective, aside from how these rules will impact the industry, it sure sounds like FTC and CFPB want to make sure mortgage lawyers like Levy have plenty of work. Knowing his priors, however, I’m confident Levy isn’t going thank regulators for the business in his unconventional lawyer blog. I can also assure you that in addition to being a good short read suitable for anyone in the mortgage business, Levy’s Musings are a lot more valuable than his free subscription price would indicate (don’t get any ideas Brian).
MQMR answers the question, “Are business purpose loans reported on the Mortgage Call Reports (MCR) and/or the HMDA LAR?” Business purpose loans are clearly excluded from the MCRs based upon the MCR definition of an application: An application is an oral or written request for an extension of credit encumbering a 1- 4 family residential property. Exclude any commercial/business/investment purpose encumbrances from reporting. Include inquiries or Pre-Qualification requests that result in denial of credit. The application date used is either (1.) The date on the initial 1003 with the borrower’s signature; (2) The date of an oral request for extension of credit, with deference to the initial 1003; (3) Inquiries and Pre-Qualification requests, if declined, should use the denial date. For HMDA purposes, an exclusion exists for loans that are primarily for business or commercial purposes unless the loan is also a home purchase loan, home improvement loan, or refinancing – in which case, it should be reported on the HMDA LAR.
Jonathan Foxx, Ph.D., MBA, Chairman & Managing Director at Lenders Compliance Group, recently wrote on several compliance “hot topics.” He wrote on the right of rescission by way of recoupment even after the lapse of the three-year period (the Dodd-Frank Wall Street Reform and Consumer Protection Act amended TILA to allow certain defenses to foreclosure but did not change the rules regarding rescission or allow TILA rescission to be used as a defense or other bar to foreclosure).
He wrote on the implications of the CFPB being considered unconstitutional (the CFPB’s rules are not going anywhere for now. However, there are some litigation challenges along the way that will need to be vetted). He also wrote on how to maintain QC independence and what kind of audit will provide oversight of the QC department and functions (every year, many testing protocols can change, statutes and investor guidelines vary, approval authorities and personnel change, ongoing change management is updated, and loan level documentation may be revised, all of which affect the effectiveness of the QC department).
There are several other topics he has written on recently. He opined on if servicers are creditors, saying that in general, TILA imposes liability only on creditors for violations of its provisions. Typically, a borrower who sues a defendant for violating TILA must tie the violation to the creditor. He wrote on how fair lending impacts reverse mortgages. Just like traditional mortgages, reverse mortgages are subject to federal laws governing mortgage lending, including TILA, RESPA, and fair lending laws such as the Equal Credit Opportunity Act (ECOA). Finally, he composed a piece on controls involving credit risk underwriting practices. This webpage lists several control areas for credit risk management.
Capital markets: bond market closed but the inflation trend is good
The bond market is closed today in observance of the MLK Day holiday, but we learned last week that Consumer prices came in as expected in December, easing 0.1 percent from November with annual headline inflation slowing to 6.5 percent from a 7.1 percent annual rate in the month prior. (A sharp decline in gasoline prices factored into the lower reading.)
The inflation report did nothing to change the expectations for two more rate increases from the Fed. Currently, the market expects both of those increases to be 25-basis points with the fed funds rate topping out at 5 percent. As inflation continues to cool, consumer expectations have eased as well. The New York Fed’s Survey of Consumer expectations reported consumers expect 5.0 percent inflation in one year and 3.0 percent after three years.
Keep your imagination in check, as we are reminded by this short video.
Visit www.robchrisman.com 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. “Productivity: More Important Than Ever” is the current blog. The Commentary’s podcast is live and at any place you obtain your podcasts (like Apple or Spotify).
(Market data provided in partnership with MBS Live. For free job postings and to view candidate resumes visit LenderNews. This newsletter is for sophisticated mortgage professionals only. There are no paid endorsements by me. For up-to-date mortgage news visit Mortgage News Daily. For archived commentaries, or to subscribe, go to www.robchrisman.com. Copyright 2023 Chrisman LLC. All rights reserved. Occasional paid job & product listings do appear. This report or any portion hereof may not be reprinted, sold, or redistributed without the written consent of Rob Chrisman.)