Thursday, May 11, 2017

STRATMOR - # of LO Comp Plans, Legal and Compliance News and Classes - Texas Home Equity News




The Will
In Annapolis, Mr. Wilson is on his deathbed and knows the end is near. The nurse, his wife, daughter, and two sons are with him.
He asks that two witnesses be present and a camcorder in place to record his last wishes, and when all is ready he begins to speak:
"To my son, James, I want you to take the Cedarwood Cove houses."
"My daughter Ellen, you take the apartments in Highland Beach."
"My son, Joe, I want you to take the offices over in the City Center.
"Sarah, my dear wife, please take all the residential buildings in Edgewater."
The nurse and witnesses are blown away as they did not realize the extent of his real estate holdings, and as Mr. Wilson slips away, the nurse says, "Mrs. Wilson, your husband must have worked very hard to have accumulated so much property."
To which the wife replied, "My husband had a paper route."

 For me this week includes Maryland, Utah, Wyoming, and California. There are all kinds of rumors out there, ranging from Donald Trump naming Brian Montgomery as the next FHA commissioner to US Bank re-thinking its role in the HFA administration business. Stay tuned. The mood out there is somewhat mixed, depending on what a given lender spent 2016 doing: making reinvesting in personnel & infrastructure a priority, or not. We'll see how 2017 rates for the latter group. It turns out states have underrated places, and since plenty of people like lists someone posted their opinion of each state's most underrated place.
 Products
 What is the "right" number of compensation plans for Originators? Lenders often talk about streamlining their compensation plans, but that plan goes out the window when recruiting big producers. According to STRATMOR Compensation Connection, in 2015 the average Retail Lender offered 17 unique compensation plans to Loan Originators and that number is expected to increase with a pick-up in recruiting. How do your plans compare to peers? Participate in the 2017 STRATMOR Compensation Connection to find out. "This year we're digging deeper into benefits to look closer at PTO, Healthcare, 401K, and Educational Assistance offerings by lenders. The deadline has been extended to May 15, so don't miss out on your chance to find out how your compensation, compensation plans and benefits compare to industry standards and peers. To participate, visit our site. For questions regarding this program, please contact us at compconnection@stratmorgroup.com."
 Mortgage Automation Software provider, Floify, announced the launch of their new Disclosure Desk, which allows lenders and compliance teams to streamline the entire disclosure process. The process of requesting, collecting, tracking, and securing borrower disclosures has remained a very manual process, often requiring dedicated teams to ensure strict compliance. Floify's Disclosure Desk simplifies the disclosure workflow between the borrower and lender, saving hours per loan and providing an elegant, modern experience for the disclosure desk associates and borrowers. Lenders can track their disclosure doc requests in their disclosure desk, get time-stamps on all borrower communications and signatures, and can easily see the disclosure status of all loans in their pipeline. Once approved, disclosure packages are securely integrated with the lender's LOS. Lenders and their teams can get more information and a demo of the Floify Disclosure Desk here.
 D+H's MortgagebotMobile - an exciting new feature of MortgagebotPOS - is a web-based solution that allows financial institutions to take accurate, qualified applications through smartphones and tablets. You might ask, who would fill out a mortgage applications on their mobile device? Or is this a necessary channel? Early adopters of MortgagebotMobile are seeing upwards of 20-50% of all mortgage applications being started, worked-on or completed in the mobile channel, most coming from non-Millennials. Can you afford to miss out on that volume? Click here to find out how you can increase your competitive advantage by partnering with D+H
 Legal & compliance
 The question out there in the industry is if standardized federal regulations would lower costs. Plenty of smart folks wonder if moves to federally de-regulate will cause "blue-state" legislatures to essentially amend state regulations to comply with previously rescinded federal regulations. Having differing regulations across different states would certainly drive up compliance costs for any mortgage company doing business across state lines.
 Trump's review of Dodd-Frank won't be complete by June as originally targeted due to staffing shortages and instead will be done in stages. The Treasury Department will first report back on what banking rules could be changed, including capital requirements, restrictions on leverage and speculative trading.
 The U.S. Department of Housing and Urban Development (HUD) announced an agreement between Wescom Central Credit Union, based in Pasadena, California, and a married couple, resolving allegations the company denied the couple's mortgage loan application because the wife was on maternity leave.
 Thank you to PrimeLending's Mark Raskin who sent me an update on Texas home equity news. Namely, the Texas State House passed SJR 60 (companion House Bill was HJR 99) meaning a proposed amendment to Section 50(A)6 of the Texas Constitution will be on the ballot this November. The TMBA has been championing this for several legislative sessions. Key provisions of the proposed amendment include: removing the "once a home equity loan, always a home equity loan" provision currently in place, providing consumers an option to refinance a seasoned home equity loan into a non-home equity product, lowering the cap on fees from 3% to 2% BUT excluding title premium, appraisal and survey expenses from the fee cap which will allow lenders to make smaller loan amounts to consumers, allowing farm and ranch property owners the ability to obtain a home equity loan while maintaining their agricultural valuation on their properties (currently only available to farm and ranch owners that have active dairy farms), and several other technical changes, updating out-of-date terminology, etc. 
 The California Department of Business Oversight (DBO) released updated information regarding compliance with Financial Code section 50204, subdivision (o) and Civil Code section 2948.5 (per diem interest). The California MBA has been working for quite some time on the issue, and is "pleased to see the Department making progress in helping our members comply with the applicable laws.
 Clayton Holdings LLC, announced that it has developed an enhanced internal audit services program. The program is designed to help bank and lender clients develop, manage and enhance their internal risks and controls programs and comply with new government-sponsored enterprise (GSE) and Consumer Financial Protection Bureau (CFPB) requirements.
 There is only one week remaining before the implementation of FHA's Loan Review System (LRS). When LRS goes live on May 15th, lenders will use the system for all new post-endorsement loan reviews and other quality control functions for Single Family Title II mortgages. During this final week before implementation, lenders are encouraged to check FHAC access and assign user roles. All users access LRS through FHAC, and must maintain a valid FHAC user ID. Each lender's FHAC Application Coordinator will need to register new users and reactivate expired user IDs for any individual that requires LRS access. For information on registering users in FHAC, refer to the FHA Connection Guide. Also, lenders should review documentation and prepare for transition. A new LRS Fact Sheet has been posted.
 Lenders Compliance Group, the nationwide risk management firm, announced a unique, cost-effective review of a financial institution's Compliance Management System. The product is its due diligence service, the CMS Tune-up! "CMS Tune-up! is a hands-on, cost-effective, due diligence review of a financial institution's Compliance Management System. The unique review is conducted by the firm's Directors and Subject Matter Experts and includes a full review, subject matter experts, executive summary, recommendations, and a risk rating. An effective Compliance Management System is comprised of three interdependent elements: Board and/or Management Oversight, Compliance Program, and Compliance Audit. Until this introduction of CMS Tune-up!, there really has been no cost-effective way to obtain an overview of how well a financial institution is complying with the regulatory mandates set forth by the Consumer Financial Protection Bureau and the prudential regulators for implementing a Compliance Management System." (For more information email LCG.)
 Today, May 11, from 2:00 - 3:00 pm EDT, Buckley Sandler will host the complimentary second of its five-part series of webcasts focused on state regulatory and enforcement issues and trends. This session will focus on current trends in the mortgage licensing and regulation space, such as the re-emerging wholesale mortgage broker channel, understanding the third-party loan fulfillment space, recent shifts in regulatory treatment of master servicers, and increased activity in the reverse mortgage lenders/servicer space. (Registration required. No outside law firms, government agency personnel, consulting firms, or media.)
 Another webinar, this one not complimentary, covers, "Financial Institution Sales Practices and Incentive Compensation Arrangements in the Wake of Wells Fargo: What Can We Expect from the CFPB?" The presenter is Chrys D. Lemon and takes place on Friday, May 26, for an hour. "'Tools and Techniques to Develop Sales Practices and Incentive Compensation that Minimize Regulatory Risk and Avoid UDAAP Violations.' Chrys Lemon will provide you with tools and techniques to develop sales practices and incentive compensation arrangements that are designed to minimize regulatory risk. Chrys will talk about how an incentive compensation program can create UDAAP problems, if it is not properly structured."
 Miami in late September is a fine place to be, and the MBA is offering RMQA17, divided into four session tracks to "provide you with timely, valuable and critical industry information. It is the one place to get best practices and the latest updates impacting risk, quality control, underwriting and fraud prevention." The tracks are "Fraud Prevention," "Loan Quality Assurance," "Risk Management and Valuation," and "Underwriting and Compliance."
 Capital markets
 Rates: up some, down some. Wednesday was a smidge lower and "wider" (compared to Treasuries) after a scattering of news and then a disappointing 10-year T-note auction. (The NY Fed released its tentative MBS reinvestments covering the May 11 to June 12 period in addition to the latest FedTrade schedule covering the May 11 to 24 period. MBS reinvestments over the coming four-week period are estimated at $24 billion - a little over $1 billion a day. Fewer loans are paying off early.) For Wednesday's session, the 10-year note closed yielding 2.41%.
 This morning we've had jobless claims (-2k to 236k - strong) and, as a measure of inflation, the Producer Price Index for April (+.5%, core +.4% - higher than expected). We commence Thursday with rates not changing much: the 10-year yielding 2.41% and agency MBS prices down a few ticks.

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