This change is HUGE and expect more closing delays! Okay, so what it really means is that after the loan is underwritten, but before funding, the file will need to be audited. The underwriter has given you one set of conditions and you may get a 2nd set of conditions from QC. So, who’s going to underwrite the loan a second time? The other bigger here is that a “defects” report (for each individual loan file) must be submitted to management on a monthly basis.
Effective July 1, lenders are required to:
1. Have a written procedure for approval or 3rd party originators (Brokers/Correspondents, etc)
2. New Requirements for QC on the PRE-Funding
3. New Requriements for QC Audit Review Process
Loans that will be considered HIGH RISK and subject to a higher percentage of pre-audit are: 90%LVT and higher; High-risk credit scores; investment properties; cash-out refis; 3rd party originations; loans originated by new employees!
Mortgage Talking Points(r) for real estate agents: “Don’t Close Late–Don’t Close Ugly” about the rules that affect closing dates on purchase contracts!
http://www.mortgagecurrentcy.com/members/mortgage-talking-points.php
Tags: audits, contol, Fannie, high-risk, initiative, lender, Links, LQI, points, pre-funding, quality, reveiw, SEL 2010-03, talking, underwriting