Let's
start with some recent notes that I have received, providing a
sense of what is on the mind of mortgage bankers.
"I'm
intrigued by Wells' new SWAT mortgage team.....underwriters and funders
running around in black spandex and balaclavas, LOs and processors
repelling down multifamily units? I hear Chase is coming out with their
new proprietary team called SEAL Team 6 1/2.....'6 1/2 days to close,'
get it? And I've heard rumors of Citi rolling out its own Delta Force.
This is all very exciting." [That all being said, the Wells'
retail portfolio retention news was a sharp reminder to independent
mortgage banks of a bank's potential.]
I received this
note from an originator in New Jersey. "We are a small company
brokering all of our loans and I find it interesting to note that there
is a divide among lenders regarding the interpretation of the final
Loan Originator Compensation Rule. Several lender bulletins
(Provident Funding, Green Tree Servicing) have stated that the rule now
prohibits any negotiated compensation, including consumer-paid (or
borrower-paid) compensation. These lenders now require that the
same compensation level apply to both compensation methods and that the
broker cannot reduce its compensation, even in a consumer-paid comp
transaction. Other lenders (New Penn, Fifth Third, Franklin American)
are continuing to allow borrower-paid compensation to vary from
lender-paid compensation as long as the borrower-paid comp is not
greater than the lender-paid level and is not lower by more than a
certain margin. This would seem to be a fairly central issue so it
is surprising to see these differences."
"Rob,
Appendix Q specifically states that 2 years tax returns are required on
self-employed borrowers. We've spoken a lot about the agency
carve out for DTI but I haven't seen anything on documentation. If
the AUs asks for one year tax returns and that's what we obtain, am I
still QM eligible under the agency carve out?" I am not an
underwriter, but Freddie Mac has plenty of them, and responded,
"The answer is 'yes'. A loan originated to our requirements
qualifies under the safe harbor (unless it is already exempt under the
ruling)."
I am fortunate
to be able to visit with local, state, and national mortgage banker
& broker associations, and I have seen their membership ranks
swell. And I am periodically asked by others, "Why should I, or
my company, join up with an association?" I took the liberty
of asking the directors/presidents of several groups, including the
MBA, for their thoughts - and thank you for responding. (This is not meant to be an
all-inclusive list of organizations!)
Lisa Vercher,
Executive Vice President of the Texas Mortgage Bankers
Association writes, "TMBA membership affords a
number of benefits including governmental and legislative advocacy,
educational programming, peer interaction, and networking
opportunities. Now more than ever membership is crucial to the
protection and prosperity of our industry. Mortgage professionals
can become leaders in the industry by actively participating as
volunteers and committee members. These leaders play an integral
role in sharing information, ideas, best practices, and current market
developments which are vital for the success of the industry. Such
leadership also provides opportunities to target trends and issues
relevant to the mortgage industry with other committee members, peers,
competitors and potential partners, while providing an opportunity
for creative problem solving as well as professional enrichment."
"The number
one reason to support your state MBA is for the legislative and
regulatory advocacy. Your state MBA is on the front line with
policy makers who make decisions that affect your ability to run your
companies and provide services to your customers. Just because you
don't have an interest in the political arena doesn't mean it doesn't
have an interest in you! Support the associations that support you and
your business" contributed Susan Milazzo, Executive Director of
the California Mortgage Bankers
Association.
Kent Carter with
the Oklahoma Mortgage Bankers
Association sent, "As was stated at the 100th
Annual MBA Convention in October, the mortgage finance industry has
moved from "too big to fail" to "too small to
comply." The advantage of receiving ongoing assistance from
the MBA as well as critical compliance training at the local and state
level allows independent mortgage companies and community banks to
remain important resources for consumers. Educational programs and
the ongoing dissemination of industry changes makes being a member of
state organizations critical to those who intend to remain permanent
mortgage lenders. Our advocacy efforts have kept some of the
overreaching aspects of Dodd/Frank from harming the consumer with
unrealistic demands. You and our state organizations will prosper
with the involvement of all mortgage professionals."
Joanne Misuraca,
Executive Director of the Michigan Mortgage Lenders
Association writes, "With all the legislative
and regulatory changes affecting the industry, being a member of your
state or local organization is the best way to keep up with it all!
Participating on its committees, attending its educational events and
networking with other members helps you stay connected and
informed. The association provides the real estate finance
industry access to the Legislature and state regulatory agencies to
help produce and maintain the type of legislation and regulatory
climate that permits lenders to fully meet the real estate financing
needs of residents. It also provides educational opportunities to
help members keep abreast of the rapidly changing mortgage origination,
underwriting and servicing environment. The MMLA maintains timely
contact with its members through newsletters, email legislative alerts
and the MMLA website to relate industry trends and developments."
Casey Fleming with the California Association of
Mortgage Professionals opines, "I
am a member of CAMP because it makes me a better mortgage
advisor. My participation in CAMP helps me in three ways. First,
education: CAMP offers educational opportunities of higher quality than
any other single source, and at very competitive prices. By
taking advantage of the opportunities CAMP presents I learn more about
best professional practices. This enhances my knowledge and
continually improves my skills and my service. The second is
information. There was a time when a loan officer only had to take loan
applications - that time is past. Today to be successful one has to
understand economic trends, regulatory changes, and financial
analysis. In CAMP I need do nothing more than attend events to
stay current. And the third is mindset. It is easy in our industry to
focus on the function of closing loans and to lose sight of the
importance of what we do. A mortgage is usually the single largest debt
any family will ever have. What we do makes a difference in people's
lives, and how we do it matters. Ethics, competence and
professionalism cannot be taught, but they can be ingrained by
associating with others who share noble values. There are many more
practical reasons to join CAMP and actively participate. But for
me, I am here because it helps me do what I do better for people I
care about."
Candice Nicodin,
President of the Mortgage Bankers
Association of the Carolinas pens, "Membership
either at the state or local level is more diverse than ever. Each
sector has wants and needs, therefore our paint brush must cover a
broader area. As our members expand we keep an open ear and
welcome change. Coming together as one unifies our position and
allows for our voice to be heard. Our arsenal of defense for our
members includes education, legislative issues or networking. It
is our responsibility to keep our industry healthy and that is done
with active participation within our membership." And Rhonda
Marcum, Executive Director of MBAC adds, "Membership in the state
association amplifies the voice of the individual members on state and
federal legislative issues impacting our industry. It provides
access to the educational venue provided through the state and serves
as an excellent opportunity to network with other industry
professionals."
Last but not
least, the nationwide Mortgage Bankers Association
(Tricia Migliazzo, VP of Membership: tmigliazzo@mba.org) supplies, "The center of
gravity in the mortgage universe has certainly shifted toward
Washington, DC with the passage of the Dodd Frank Act, the
implementation of more than 4000 pages of new federal rules, and the
creation of new federal supervision and examination agency for
independent mortgage bankers. It's more important than ever that
community-based lenders be engaged with the MBA's federal advocacy
efforts to create one loud and powerful voice for housing finance
issues. That said, the role of the states remains critically
important. We continue to see state policy makers trying to piggy
back on the federal rules, creating costs, confusion and compliance
risks that fall most heavily on state chartered lenders. In addition,
the state and local MBAs provide critically important of grassroots,
boots-on-the-ground support for our federal advocacy efforts, providing
invaluable support for our industry issues from companies and employees
in the districts and home states of the Representatives and Senators.
That is why MBA has spent the past two years strengthening our
partnership with the state and local MBAs. We have redoubled our
efforts to provide timely information and grassroots engagement
opportunities to the states on federal issues."
The MBA
continued. "We have dedicated MBA significant staff resources to
provide data, policy analysis and advocacy support to the state
associations on the issues they are battling in state capitols across
the country. Most important, this partnership is being heard
by policymakers and delivering wins for the industry. Some
examples: Last fall, 17 state and local associations, working with the
MBA, submitted letters to the 6 regulators working on the QRM rules
urging that the QRM definition equal the QM, and we are winning that
battle. In April 2013, more than 25 state and local associations came
to Washington to lead their delegations on Capitol Hill as part of
MBA's National Advocacy Conference. In 2013, MBA worked with our state
associations to secure adoption of the uniform state Safe Act test
(UST) by 39 regulators in 37 states and territories. Last year, MBA
worked with the state associations in 6 states to block or amend
legislation that would have created state servicing standards that
duplicated or conflicted with the new federal rules. We believe in this
partnership and are committed to making it stronger. We are
strongest as an industry when every company joins and supports their
employees' participation in the local, state and national MBA."
Testimonials for
MBA membership:
"Our annual
MBA Membership dues are the best investment we make every year."
(Dan Klinger, K. Hovnanian American Mortgage, LLC.)
"Through
active member engagement, you can lend your expertise to MBA's
grassroots and national policy and legislative agendas to truly be the
voice of the industry as the future of real estate finance in America
is determined." (Bill Cosgrove, CMB, 2014 MBA Chairman-Elect
President and
CEO, Union National Mortgage Co.)
"We get an
opportunity to actually meet with legislators, decision makers, and
regulators. Those are the folks who are formulating what the future of
our industry is going to look like." (Chris George, CMG
Financial.)
"I've
had the opportunity to testify on Capitol Hill - and what it let me see
was how well-respected MBA is on the Hill - and how we speak with one
voice." (Regina M. Lowrie, CMB, Vision Mortgage Capital.)
"New rules
are complex, but they are not insurmountable to understand and
implement. My company needs resources, education, and a voice in
mortgage lending to operate in a compliant and profitable manner. That
is why we are an active member of MBA." (Fowler Williams, CMB,
Crescent Mortgage Company.)
"We started
five years ago - and five years later we're five times the size. And a
large part of that is due to the Mortgage Bankers Association."
(Philip DeFronzo, Norcom Mortgage.)
"For more
than ten years we have participated in MBA's peer-group benchmarking
surveys. The information delivered to participants helps us recognize
best practices, plan for the future and learn what others are doing to
excel in the marketplace." (David Motley, CMB, Colonial National
Mortgage.)
Thanks everyone!
Rob
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