Things to Know from the Compliance Team
- ATR/QM – Under the ATR/QM screen in forms, Eligibilty tab, the system will auto select the appropriate drop downs based on data entered. If the correct drop downs are not reflected in this screen means there is an issue with the loan and you need to stop. Will also reflect in Mavent as a fail or warning. Here is what the fields should read:
ATR = Qualified Mortgage
QM = General QM
ATR = Qualified Mortgage
QM = FHA QM
ATR = Qualified Mortgage
QM = VA QM
- As mentioned several times, if you send LE or CD for esign and borrower wet signs the document, but then goes into their account and esigns, the esignature overrides the wet signature in encompass. We cannot override this and your closing will need to be pushed back. Suggestion: If you know in advance that you are going to have your borrower(s) wet sign, let team know to send US Mail versus esign, this will eliminate the issue as document will not show in the borrower(s) account.
- High Cost and High Priced Mavent fails and warnings: Note: warning may be reflected, but not needed due to product, just means you need to review to make sure you are clear.
- High-Cost fail/warning – not allowed (fees need to be reduced to clear)
- High-Priced fail/warning
Higher-Priced Covered Transaction – FHA Qualified Mortgage Rate (FHA only AKA Rebuttable Presumption)
If fail, must meet residual income/reserve requirements to clear
Higher-Priced (FED) Review
Conventional – Need Residual Income/Reserve requirements to clear
*Loan requires escrows
FHA – FICO must be above 620
- If still using GS Application, the subject property address has been blocked. This is due to the new URLA. Anything entered on the GS application does not carry over to the new URLA as the subject property is a new field ID.
- URLA fails apply to closing disclosures as well as initial application disclosures. If you have an URLA alert when trying to send closing disclosures, need to stop and fix fail before sending documents. Documents will send, but not the URLA.
- Signing disclosures and Holidays. To clarify, If you are signing on a Holiday, this day does not count in rescission or as day to meet any requirements. So for example, when issuing the ICD and to meet the 3 day prior to close requirement, a holiday is not counted in that 3 days. If holiday is on a Monday and closing is on a Thursday, ICD would have to be issued by that Saturday (or Friday) prior to.
- Reminder, Redisclosure does not check to make sure your fees are entered correctly, please review loan before approving redisclosure.
- Redisclosing on a CD. We have added to the Closing Command Center the “LE Redisclosure Status box”. If it reflects “Pending/Problem” please let the Redisclosure team know you are redisclosing on CD so they can clear out of their queue. There should already be a corresponding ticket.
- Removing a co-borrower does not require redisclosure. You can remove and proceed.
Loan Status Corner
- A friendly reminder to check the last AUS run prior to final approval.
- When issuing a denial with borrower pairs (2 separate borrowers), need to complete all checkboxes etc. for all borrowers. Information does not carry from one to the other.
- Loans withdrawn or dispositioned in the previous year cannot be reactivated. A new file will need to be restarted.
Post Consummation Corner
- Please make sure the estimated value is entered into encompass. Finding loans where this has been removed which stops us from printing a PCCD (Post Consummation CD)
- Contact information still missing from files. These need to be completed in their entirety, is resulting is PCCD needing to be issued to clear loan for purchase. “1” is not an option….. This is also located on the closing command center so can be easily reviewed prior to ICD being issued or final docs.
- Issuing PCCD and tolerance cures not caught at closing. Once an ICD had been issued, it is up to the closer to monitor changes, COC’s and need for tolerance cures. If you are unsure if a tolerance cure applies, please reach out to Jen Bailey for confirmation.
Nothing new from the insuring team, but here’s a tidbit from Susan Lakovic on VA loans:
If you gross up and income (SSI, Pensions, ect) the amount that was grossed up must be subtracted from the residual income portion
Pension is 1500.00 x 125% gross up = 1875.00 used for income to qualify.
The gross up portion 1500.00 – 1875.00 = 375.00
If you do not gross up the income, then you do not have to deduct.
There are times that not grossing up the income actually may be more beneficial to meet the residual requirements.
VA will typically approve a higher ratio loan, but will never approve a loan that doesn’t meet residual requirements.
Any suggestions, topics, or questions you may have, you can always reach out to me directly for review at email@example.com
If you are having any issues or need assistance, please reach out to Help Desk @ HELP@goldstarfinancial.com