Oct. 6: Management job & subservicing product; more Consent Orders against lenders; upcoming events

Thanks to the internet, you are reading this commentary. Ask Marriott how that’s working out for them: Marriott was fined $600,000 by the U.S. Federal Communications Commission for blocking hotel customers from connecting to the internet on personal Wi-Fi networks in order to force them to pay for the hotel’s network. (Marriott employees blocked mobile “hotspots” at the Gaylord Opryland Resort & Convention Center in Nashville, Tennessee, while at the same time charging consumers, small businesses and exhibitors as much as $1,000 per device to access Marriott’s Wi-Fi network.) Under a consent decree with the FCC, Marriott must stop using Wi-Fi blocking technology and file compliance and usage reports every three months for three years, the FCC said.


Switching over to something of interest for job seekers, CUSO TruHome Solutions, LLC is seeking a highly motivated, influential and proven leader to manage and direct the overall operations of TruHome Solutions as President. This position is responsible for providing executive oversight and executing the strategic vision of the Board. This person must possess a proven track record of effectively managing an organization’s growth and financial objectives. Strong communication skills, the ability to inspire confidence and effectively manage an ever changing environment are required. This position is responsible for creating and maintaining a high level of service and integrity throughout the organization by promoting and leading the strategic partnership between TruHome Solutions and their clients. TruHome Solutions, LLC is an organization that offers first in class benefits, great work life balance, proven stability and competitive compensation! If you or someone you know may be interested, please email for a complete job description or forward resume to Karen Steen.


And for servicing, mortgage servicing continues to evolve with increased regulatory and compliance requirements, which has driven up the cost of servicing and has further increased compliance risk. Subservicing may be the best option to navigate these risks and to keep costs under control.  PHH Mortgage has been originating and servicing residential mortgages for more than 25 years and prides itself on providing a consistent customer experience and being a trusted partner. Currently servicing 1.2 million loans with a total loan servicing portfolio of $226 billion, PHH has the scale, stability and experience that you should look for in a subservicing partnerPHH will be attending the Mortgage Bankers Association Annual Convention, October 19-22, and the American Bankers Association Annual Convention, October 19-21. If you would like to schedule an introductory meeting at the MBA convention or phone call to speak with a subservicing PHH team member, contact Rob Seltzer or David Schaede. To schedule a meeting at the ABA convention, contact Len Patton.


A quick note: on Friday the commentary posted an ad for Franklin American’s wholesale group. “FAMC is looking for wholesale AEs in UT, MN, WI, CO, TX, Central CA, Southern NJ, Chicago IL, Columbus OH, Cleveland OH, and Detroit MI.” Some readers did not receive the correct website address – it should be http://whyfamcwholesale.com/. Or e-mail Jennifer Rader for more information. Franklin American Mortgage is FHA Direct Endorsed (DE), VA Automatic and LAPP Approved, FNMA/FHLMC and GNMA approved seller servicer.


Congrats to Meg Burns who has been named Managing Director at The Collingwood Group, a Washington, D.C.-based business advisory firm. Since 2010, Burns has served at the Federal Housing Finance Agency (FHFA), most recently as Senior Associate Director for Housing and Regulatory Policy.


Before we jump into the “heavy” stuff, next Monday, October 13, is Columbus Day (with all of its Native American controversy) and Tuesday November 11th is Veterans Day – both Federal holidays. Most lenders are open, however. As a reminder, for disclosures and loan funding purposes, the rule is related to whether mail can be received or not. If the post office is closed and there is no mail delivery, it is a holiday. (The list of federal holidays referred to in Reg. Z are New Year’s Day, January 1, Birthday of Martin Luther King, Jr., the third Monday in January, Washington’s Birthday, the third Monday in February, Memorial Day, the last Monday in May, Independence Day, July 4, Labor Day, the first Monday in September, Columbus Day, the second Monday in October, Veterans Day, November 11, Thanksgiving Day, the fourth Thursday in November, and Christmas Day, December 25.) Both Columbus Day and Veterans Day are federal holidays meaning we don’t count them for the purposes of the initial 7-day Reg Z waiting period, the 3 day re-disclosure waiting period, and right of rescission. For the timeframes on initial disclosures, RESPA requires that the initial disclosures be sent within 3 business days.  Business day means a day on which the offices of the business entity are open to the public for carrying on substantially all of the entity’s business functions.


The CFPB and other regulators share a certain percentage of information, much of it from state-level examiners but also from those at the Federal level. For example, here is a HUD OIG Audit involving Cornerstone Home Lending in Houston, Texas involving MSAs and other issues, along with a corresponding story in RESPANews.


And Georgia is enforcing its rule about felonies. Many people in lending may not know companies can’t employ anyone (anywhere in the company) with a felony for (usually) 7 or more years – some never. Even the janitor must be clean. Late last week word spread: “On October 1, 2014, the Georgia Department of Banking & Finance entered into a Consent Order with Hometown Lenders, LLC, NMLS No. 65084, located at 310 The Bridge Street, 4th Floor, Suite A, Huntsville, Alabama, and its owners, William E. Taylor, Jr., William E. Taylor, Sr. and Byron Heath Quick. The Consent Order was entered to resolve a Notice of Intent to Revoke and Orders to Cease and Desist issued to Hometown Lenders and its owners for employing two felons and transacting business with an unlicensed mortgage processing company. (The Department is the state agency that regulates and examines Georgia state-chartered banks, state-chartered credit unions, and state-chartered trust companies…. mortgage brokers, lenders and processors, mortgage loan originators, check cashers, sale of check companies, money transmitters, international banking organizations, and bank holding companies conducting business in Georgia.)


In the last few weeks I have been in South Carolina, Colorado, Georgia, California, and Arizona. Many people ask me about sub-prime lending. Yes, I believe there will come a time when sub-prime mortgages will make an historical return to the norm in the marketplace. I also believe there will be a time when man walks on the surface of Jupiter’s moon Titan, it’s just the “when” portion of those statements I have a problem defining. If you missed the short article in the New York Times about this topic, it’s worth three minutes of your time. Zillow on the other hand, attempts to quantify the demand (pent up or real) in its Supply and Demand Dynamics in Subprime Mortgage Markets. Using a unique database of loan requests and responses through its Zillow Mortgages (an online marketplace that connects mortgage borrowers and lenders) they use three sets of metrics to assess the underlying demand and supply dynamics driving sub-prime mortgage markets over the period covering June 2011 through April 2014. What does the data suggest? Zillow writes, “…demand has grown most dramatically among borrowers with higher credit scores (640 or higher), nearly tripling between June 2011 and April 2014. By contrast, demand among borrowers with slightly lower credit scores—those rated between 600 and 639 who are likely to benefit most if lending standards ease—has grown roughly in tandem with borrowers with credit scores below 600 who are largely excluded from mortgage borrowing regardless of the ease of credit.”


Let’s move on to some upcoming October events of note, in random order…


The MBA will hold a special webinar on October 14, 2014 from 2 PM to 3 PM ET with USDA staff who will discuss the benefits of the Automated Loan Closing Systems and answer your questions. Already using the system? Feel free to participate in the webinar to ask questions and improve your knowledge. Access Info: http://mba.adobeconnect.com/usdaga/, (800) 768-2983, code 5572870.


The Michigan Mortgage Lenders Association presents its “Mortgage Go Round Workshop” in Grand Rapids 10/16, this round table format has plenty of interaction among the attendees discussing today’s hottest topics in mortgage lending. By the way, MMLA members can still get the early bird pricing to attend the MBA Convention in Las Vegas October 19 -22. Just click here to use this registration form to get the discount.


Plaza Home Mortgage is offering industry and product trainings. The month of October includes: Ask the Underwriter: Reverse Mortgage Tuesday, October 7 at 11 am Pacific; Loan Prospector®: Interpreting the Feedback Thursday, October 9 at 8 am Pacific or Monday, October 13 at 11 am Pacific; How to Present a Reverse Mortgage Wednesday, October 15 at 11 am Pacific; CFPB Compliance Management System Wednesday, October 22 at 11 am Pacific.


AllRegs has the 7 and 8 hour Federal Safe Act CE courses you need to stay licensed and compliant and your credit banking fees are included with registration. NMLS-approved SAFE CE training is just a click away.


On the day before Halloween, CFPB updates web seminar on October 30th will help you get a better understanding of the impact of the CFPB’s new mini-correspondent guidance and provide practical advice as to how lenders of all sizes can adopt renewal processes, modify business relationships and implement internal infrastructure to remain both competitive and compliant.


Colorado Association of Mortgage Professionals is offering a Webinar October 15th. This class introduces the Real Estate Agent and Mortgage Professional to the new Closing Disclosure established by the Consumer Financial Protection Bureau (CFPB) and the associated changes affecting the RESPA documents, Good Faith Estimate, Truth-In-Lending, and HUD1/HUD1A Settlement Statement.


Federal Reserve is offering an Outlook Live Invitation on Wednesday, October 22, 2014 at 11:00 a.m. PST (2:00 p.m. EST). Register here as the topics will include a variety of emerging fair lending issues. Speakers at this event will represent the following seven federal agencies.


Mountain West Financial Wholesale is offering VA Lending Certification Webinar on October 9th.


The National Association of Hispanic Rea Estate Professionals, NAHREP, announced its National Convention and Latin Music Festival will take place in Los Angeles, on October 12-14, 2014. Registration information includes list of events with approximately 2,500 participants expected to attend the conference, which is focused on education, networking, awards programs and entertainment.


In partnership with Freddie Mac, Stearns Lending is offering Loan Prospector® training webinars available to Stearns approved brokers. Register for October 14th – topics will include Integration of SNAP / Loan Prospector (LP) and an Overview of Loan Prospector: How Loan Prospector works and interpreting the results.


We continue to receive conflicting numbers on the strength (or weakness) of the U.S. economy. It is nearly impossible to argue that we are in a recession as overall things continue to improve, in some cases at least remain stable. On the housing front, I have lost track of what new home sales, existing home sales, pending home sales, the FHFA index, the Case-Shiller Index, etc. have all showed us in the last month. But autumn and winter are rarely times for great appreciation. The impact of rising rates may be minimal as higher rates usually mean a healthier economy, and some experts think that improvements in employment and credit availability will increase the demand and opportunities for first time home borrowers.


For the bond market, which includes MBS, we’ve been in the same range since MLK Day: the 10-year has stayed between 2.80% and 2.35% – (2.65% and 2.35% since May) and we’re on the lower end of that. Decent news out of the United States has been balanced against problems overseas which in turn drive money managers to buy our securities. Don’t look for that to change this week as we have very little scheduled market-moving news. There is zip today and tomorrow. Wednesday afternoon we’ll have the Fed’s releases of the minutes from its Sept. 16-17 FOMC Meeting. Thursday is Initial Jobless Claims, along with some inventory and trade figures, and then on Friday some import price indices. The 10-yr’s yield at the close of Friday was 2.45% and in the early going today we’re at 2.43% and agency MBS prices are better by a smidge.



(Part 1 of 2 of some “oldie but goodie” word puns.)

Those who jump off a bridge in Paris are in Seine.

A man’s home is his castle, in a manor of speaking.

Dijon vu – the same mustard as before.

Practice safe eating – always use condiments.

Shotgun wedding – A case of wife or death.

A man needs a mistress just to break the monogamy.

A hangover is the wrath of grapes.

Dancing cheek-to-cheek is really a form of floor play.

Don’t make German sausage jokes. They are the wurst.

Does the name Pavlov ring a bell?

Reading while sunbathing makes you well red.

When two egotists meet, it’s an I for an I.

A bicycle can’t stand on its own because it is two tired.

What’s the definition of a will? (It’s a dead giveaway).

Time flies like an arrow. Fruit flies like a banana.

In democracy your vote counts. In feudalism your count votes.




(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.)

Rob Chrisman