Ops VP Weighs In On TRID

Valentine's Day is fast approaching, and in the world of romance, one single rule applies: Make the woman happy. Do something she likes and you get points. Do something she dislikes and points are subtracted. You don't get any points for doing something she expects. Sorry, that's the way the game is played. Here is part 2 (of 4) of a guide to the points system:

 

HER BIRTHDAY

You take her out to dinner................ 0

You take her out to dinner and it's not a sports bar....+1

Okay, it is a sports bar..........-2

And it's all-you-can-eat night....-3

It's a sports bar, it's all-you-can-eat night, and your face is painted the colors of your favorite team......-10

 

A NIGHT OUT WITH THE BOYS

Go with a pal.........................+5

The pal is happily married............+4

Or frighteningly single...............-7

And he drives a Lamborghini...............-10

With a personalized license plate (GR8 NBED)........-15

 

"Have you heard the latest statistics joke?  Probably." CNN reports the latest data from the IRS finds the top 10% of Americans make $128,000 in minimum adjusted gross income versus $429,000 for the top 1.0% and $1.9mm for the top 0.10%. To reach the top 0.01% you would need $9.5 million.

You may already know that the largest generation in history is sitting on $4 trillion in equity. On Thursday, February 11 at 2PM EST, National Mortgage Professional Magazine hosts the "Moving Forward with Reverse" complimentary webinar presented by American Advisors Group. They'll introduce you to the NEW reverse mortgage and highlight why it's time to empower this generation by "Moving Forward with Reverse!" Attendees will discover how easy it is to get started. The Home Equity Conversion Mortgage reverse mortgage is more similar to a traditional forward loan than ever! Did we mention that broker commissions range from $4K to $12K?

Sierra Pacific Mortgage continues their focus of featuring industry experts on their Market Power webinar, hosted by Kelli Brookman.  Who is the "expert" this month?  Well, it's yours truly - Rob Chrisman.  If you are trying to determine why rates are doing what they are doing and if that is going to change, how to read the CFPB and their enforcement actions, and what lender CEOs are concerned about, then join in on the fun February 18th from 11:00  - 12:00 PST (2-3 EST). Sierra Pacific Mortgage believes the key to success is sharing expert knowledge, so the webinar is open to all.

Arch MI is gearing up for spring home buying with a variety of webinars, click a link to register:

Understanding the Aspects of a Loan File Tuesday, February 9th, 2016 - 10am Pacific, Mortgage Fraud:Everything Old is New Again Wednesday, February 10th, 2016 - 12pm Pacific, Navigating and Evaluating Personal Tax Returns Thursday, February 11th, 2016 - 10am Pacific, Processing:Using the 1003 as a Roadmap Tuesday, February 16th, 2016 - 12pm Pacific, and Creating Separation Between You and Your Competitors Wednesday, February 17th, 2016 - 12pm Pacific.

 The Washington Mortgage Bankers is having economist Elliot Eisenberg speak at its upcoming meeting on February 23^rd.  

 Join BakerHosteler, co-sponsored with the Ohio Bankers League, for its Financial Services Risk Summit, on Wednesday, March 3 at The Ritz-Carlton in Cleveland. This daylong seminar will include high-profile government speakers including Calvin R. Hagins, Deputy Assistant Director for Originations at the Consumer Financial Protection Bureau, and Steve Dettelbach, United States Attorney for the Northern District of Ohio, in addition to other leaders from the financial services industry. The event will feature discussion on a full spectrum of risks faced by banks, mortgage lenders, credit unions, loan servicers, and other credit issuers aiming to stay ahead of high-stakes litigation and rapidly changing regulatory and compliance issues.

 The Colorado Mortgage Lender Association knows how to have a good time, and in this case its Fort Collins Brewery Tour is coming up in March. Register now for the 2016 Northern Chapter Tour and bring 1 Realtor Guest for free.

 The MBS Boot Camp is back on March 3^rd and 4th with the CFA Society of Los Angeles.This 2-day program is designed to introduce participants to the broad variety of mortgage and MBS products, explain technical aspects of MBS performance, and demonstrate why and how different types of MBS structures are created. Run by industry vet Bill Berliner of Kinecta Federal Credit Union, participants will explore a wide variety of concepts while gaining experience in modeling cash flows, market execution and risks.

 And the CFPB is coming out with a "Know Before You Owe Mortgage Disclosure Rule - Construction Lending Outlook Live Webinar" on Tuesday 3/1 at 2PM EST (11AM PST). "Please join us for a webinar on the Know Before You Owe mortgage disclosure rule. This webinar will address questions that the Consumer Financial Protection Bureau (CFPB) has received relating to the rule in the context of construction lending. Additional information and resources related to the Know Before You Owe mortgage disclosure rule may be accessed at the CFPB's website at: http://www.consumerfinance.gov/regulatory-implementation/tila-respa/."

 Speaking of TRID and the CFPB, the impact of the CFPB's "Know Before You Owe," its 3 day period, and its workarounds continue to present issues and problems, and there is no doubt that these are impacting the consumer in ways unforeseen by the CFPB.

 Marc Silvera and David Lee Toste from U.S. Mortgage Corporation sent along this note on another industry, but the policy could impact mortgage banking. "This article was from Sunday's NY Post. I thought I'd share with you as it's a pretty damning column from Paul Sperry on how the CFPB went about with their 2013 actions against lenders in the auto-lending industry. If true, scary stuff indeed."

 Penny Nelson, SVP of Ops with outsource provider Altavera, sent me a note titled "TRID in the Trenches." "Rob, having been an industry participant since before APR became an inexplicable fact of life and in my role as an ops manager for the last 25+ years, I have acquired quite the historical perspective of compliance regulations and implementation of same. I currently manage operations for an outsource provider where we are shoulder to shoulder with our clients in the trenches.

  "Early feedback from our processing and closing staff, recent confirmed closing delays related to TRID along with documented evidence of high TRID compliance fail rates in closed loans, has compelled me to share some observations and insights. Our staff is working with companies who are totally buttoned up but did initially struggle with the changes required of TRID. A variety of problems were seen at the time the files arrived in closing, but three factors were common, individually or in combination: Errors and omissions on the initial LE or subsequent LEs, changes made to LEs without a valid Change of Circumstance, and initial CDs were sent out before the file was properly reviewed and reconciled in order to start the three day clock.  In some cases, the initial CD was sent before the file was clear-to-close.

 "As joint efforts were made to remediate the early challenges, lessons were learned which I would like to share with others who still find they are struggling. First, any staff member touching an LE or CD needs to thoroughly understand the details of TRID regulation and access must be strictly controlled. TRID has brought a level of complexity that makes the very best software and flows, although absolutely necessary, secondary to the human intelligence needed to properly analyze, manage and input the data. Expecting templates and software to do the heavy lifting was found to be inadequate in itself.

   "Extreme diligence and care must be taken with the Initial LE. The level of detail must equal that of the final CD. Sales teams must get on board with this necessity, and expect to provide terms and fees accordingly. Shortcuts at this stage can be costly in every way imaginable.

 "Detailed policies and procedures must be put in place to drive TRID compliance throughout the entire operation with hard stops which are actually enforced when necessary, even when it hurts. Our industry can do this!" Thank you Penny.

 It's been 4 months since TRID requirements went into effect. And, to find out whether all the lender apprehensions and dire predictions are coming true, STRATMOR has just launched "STRATMOR Spotlight" survey entitled "4-Months of TRID - Impact and Experience." This important survey addresses such questions as: How well did the LOS vendors meet TRID requirements? What's been the overall experience thus far? What process changes have lenders implemented? What's worked well? What hasn't? What's TRID cost and how have these costs been absorbed? STRATMOR Spotlight is the new name STRATMOR's given to what was formerly known as the STRATMOR PeerViews Program. The survey is free and lenders pay a modest fee only if and when they choose to view and download survey results, which are expected to be available by mid-March. This approach allows you to know how large the survey response has been before purchasing the survey.

 Welcome to "Fat Tuesday" - Mardi gras. Once again lenders are brushing off their renegotiation policies as the 10-year T-note closed at 1.74% yesterday - its lowest level in over year a year. Agency mortgage-backed security prices, of course, are lagging due to early pay-off fears - although those in the business believe that recent mortgage originations are much more "sticky" due to the hassle cost of refinancing. Do consumers really want to go through the process again to save $90 a month?

 Yes, the Treasury market rallied sharply Monday in a curve-flattening trade today as investors scrambled for safe-haven assets from gold to Bunds amidst worries about major international banks. Interestingly gold touched its highest level since June 2015. Global equities sold off as worries about the effects of negative policy rates about lenders' interest rate margins in the Eurozone and a flattening yield curve in the U.S. led stock markets to break technical support levels. And lenders everywhere are facing margin calls from investment bank's MBS trading desks given the rally.

 With China closed for the week (New Year's holiday) and no news of importance coming out of the U.S. today, there isn't much to stem a) the stock markets selling off, and b) the continued flight into bonds. Too much of a good thing isn't good, however. We have a $24 billion 3-year note auction later today. In the very early going we're pretty much unchanged from Monday's closing price levels.