Documentation Requirements Continue to Change

By rchrisman@robchrisman.com

 

(Rated PG: Adult situation.)

Two guys are playing golf. The women in front of them are really taking their time and are slowing the men up.

So one man says to his friend, "I'm gonna go ask those ladies if we can play through."

He starts walking, but about halfway there, he turns around. When he gets back, his friend asks what happened.

He replies, "One of those women is my wife, and the other is my mistress. Why don't you go talk to them?"

So the second man starts to walk over. He gets halfway there and turns around.

When he gets back, his friend asks, "Now what happened?"

To this he replies, "Small world."

 

The other day I was reading about customer loyalty programs. My cat Myrtle was sitting nearby, and seemed to have a look on her face as if to ask, "How about we buck the trend and create a 'customer disloyalty' program?" Seriously, it is hard for a non-bank residential lenders to offer loyalty programs, but depository banks certainly have that tool up their sleeves. For example, here's an example of cheaper auto loans for depositors.

And tomorrow REMN Wholesale is helping to host the "Inside The Renovation Studio" Webinar. One of the best ways to convert today's renters into tomorrow's home owners is to leverage the power of renovation lending. And when it comes to reno products, few companies have the expertise that REMN Wholesale does. REMN, in conjunction with National Mortgage Professional, will be hosting a very unique webinar that will answer questions about reno products and present the best ways for marketing them to Realtors, as well as the new generation of millennial home buyers and other renters who simply don't realize the opportunities a renovation mortgage can provide them with. The "Inside The Renovation Studio" video webinar will feature REMN's Carl Markman, Pam Seifertand Damon Richardson in an interactive presentation that will allow viewers to ask questions and receive clarification on reno-related topics. The online broadcast will take place on Thursday, May 12. Due to the nature of how this webinar will be produced, space will be limited, so register here.

 In other company news, First Guaranty Mortgage Corp. is acquiring goodmortgage.com, an online mortgage lender, as FGMC plans to expand its digital presence. As reported by HousingWire, Goodmortgage.com was founded in 1999, and provides residential mortgage loans in 18 states and Washington, D.C. According to the company, goodmortgage.com was one of the "early pioneers" in online direct consumer lending, and its robust online lending platform made it attractive to FGMC. Goodmortgage.com is based in Charlotte, North Carolina, and until this sale was company was privately held and run by its founder & CEO, Keith Luedeman.

 On the flip side, Ditech Financial, a division of Walter Investment Management, announced layoffs of over 100 people in its collections department in Missouri. Like other lenders, with the number of troubled loans diminishing the industry needs fewer personnel in this channel. (Displaced employees can always post a resume for free at www.LenderNews.com.)

 And in keeping with publicly held companies whose earnings have been marred by servicing value changes, Stonegate Mortgage Corporation's earnings failed to meet estimates. Its operating EPS excludes a $35.7 million negative MSR (mortgage servicing rights) mark, $0.3 million of stock comp and severance, and includes ($1.6) million of tax adjustments. Analysts pointed to the usual culprits for not meeting forecasts: lower gain on sale income, lower interest income, and lower loan origination fees - all rarely a recipe for success. For example, Stonegate's gain-on-sale margin came in at 119 bps, up from 100 bps last quarter but below what some were hoping for. Mortgage origination volume fell to $1.94 billion from $2.27 billion in 4Q. Interest rate locks per day averaged $49.5 million in 1Q versus $44.1 million in 4Q15, and SGM's average origination volume per business day was up 18% Y/Y to $36.8 million in April and average mortgage loans locked per business day was down 1% Y/Y to $49.2 million in April. Its servicing portfolio was $18.1 billion of UPB, up from $17.5 billion in 4Q. Servicing fee income of $13.4 million was down from $13.8 million in 4Q.

 While we're on Stonegate, it recently announced that Robert O'Branovich has been named Mid Atlantic Regional Sales Manager. "In this role, he will lead the Mid Atlantic Region's Third Party Origination sales teams, selling products in the company's four TPO channels - broker, non-delegated correspondent, delegated correspondent and bulk mandatory. He will report directly to John Pantalone, SVP TPO Eastern Division."

 Stonegate's, and every other lender & investor's, documentation requirements, policies, and procedures continue to change. Let's take a look at a recent sampling of alterations.

 AmeriHome has partnered with AllRegs by EllieMae to provide an additional publication platform for AmeriHome resources, through the AllRegs Online Investor Library. All AmeriHome announcements and documents will continue being published on SellerWeb as it will continue to be the official publication site for AmeriHome announcements, guides, and related resources.

 A while back Ethos Lending received guidance from The California Bureau of Real Estate and its investors. Ethos can accept a borrower-signed copy of the Ethos-issued Loan Estimate AND a borrower-signed copy of the CA Bureau of Real Estate Disclosure as an alternative form of compliance with the state's requirement. There are two different ways in which to meet the requirement. Provide the MLDS prepared by the broker and signed by the borrower OR Provide a borrower-signed copy of the Ethos-issued Loan Estimate AND a borrower-signed copy of the CA Bureau of Real Estate Disclosure. Both of these items are included in the initial disclosure package.

 To help expedite your file through LHFS, please make sure that the "Attestation Clause" box is checked (above signature line). Click here for the updated form.

 PennyMac has created a TRID reminder highlighting specific delivery requirements to help ensure loans are compliant and purchased in an efficient manner.

 Effective for closing packages received April 23^rd, Citi clarified the requirements for submission of Closing Disclosures with the following update to the Critical Documents listing: In non-escrow states, The Closing Disclosure signed and dated at closing/consummation by all consumers. In escrow states, Option 1: The Closing Disclosure signed and dated at consummation by all consumers, used for final disbursement and identified as such. (For example: Marking disbursement Closing Disclosure with "Final" or "Disbursed".) Option 2: The Closing Disclosure signed and dated at consummation by all consumers AND the Closing Disclosure used for final disbursement identified as such. (For example: Marking the disbursement Closing Disclosure with "Final", "Disbursed", or "Post-Consummation". Updates and clarifications have also been made to the Document Requirements section for Purchase and Refinance transactions and for Closing Disclosure submission when a change is found after Loan purchase.

 Mountain West Financial has updated it requirements on Change in Circumstance procedures.

 And Mountain West Financial's Veteran's Eligibility must be entered into PriceMyLoan so that the VA Funding Fee is calculated and disclosed correctly. As a Best Practice, it is recommended that the Initial Disclosures be prepared to reflect the highest VA Funding Fee possible until the Veteran's Certificate of Eligibility is received to verify Entitlement. Please refer to the steps found in the Registering a VA Loan and Enter VA Funding Fee in PML how to document located in the How to section of the BOLT Page, or by clicking here.

 Wells Fargo Funding clarified its policyon its rate/term refinance definition to clarify that the purpose of any simultaneous secondary financing does not impact the new first lien's classification as a rate/term refinance. In addition, Wells has expanded its policy by removing its six-month seasoning requirement for conventional conforming, cash-out refinances. Also noteworthy, Rels Valuation's Share with Investor function is set to be retired May 20, 2016. Sellers who currently order directly from Rels Valuation and use the Share with Investor function to send appraisal data to Wells Fargo Funding will need to migrate to its Direct Deliver functionality.

 Sun West accepts initial loan application and applicable disclosures executed prior to closing using electronic signature ("e-signature") if in compliance with the requirements of the Federal E-Sign Act. At the time of loan submission, you must submit an Audit Trail (such as a Certificate of Completion from an Authorized E-Signature Vendor) available in the HELP section of sunsoft.

 CoreLogic announced the upcoming release of Trestle by CoreLogic, a software solution suite that will fundamentally change the offering of multiple listing service (MLS) data to brokers and their vendors. Trestle will be the real estate industry's first "data mart" to benefit brokers, their technology partners, and the MLSs in which they participate. By implementing Trestle, brokers, and the technology providers supporting them, will be able to develop solutions combining MLS content with gold-standard data from CoreLogic, bringing unprecedented power to their websites, mobile solutions and in-house systems. For each MLS, Trestle will provide administrative controls to assure its listings appear only where authorized. Trestle will also maintain RESO standards with respect to the data dictionary and API access, removing a future concern and cost for MLS participants.

 Turning to the bond market & rates, the low volatility, low interest rate environment continues. Low volatility lowers hedging costs, a good thing for companies especially if profit margins need to be cut. The trend continued Tuesday despite a sharp rally in global equity and oil markets. There was little news of substance in the United States although the job openings data was better than expected and will allay some investor concerns that the jobs market is cooling off following Friday's release of the April jobs report. And the $24 billion 3-year Treasury auction was met with strong demand.

 Today the lack of news continues, and the mainstream press (no one has ever accused me of being mainstream!) is focused on the government denying the Staples/Office Depot merger. We have to have choices buying copy paper and printer cartridges! Mortgage Bankers Association Applications for the May 6 week rose by +0.4% following the prior 3.4% decline. Refis were up .5% and purchases were +.4%. Refis still account for roughly 53% of overall applications.

 Later today you can scrape your pennies and bid on the Treasury's $23 billion 10-year Treasury auction (results at 1PM EDT). Don't want to tie up your money for ten years and earn only 1.76%? There are plenty of investment opportunities, but none as safe, right? This morning the 10-year is still sitting around 1.75% with agency MBS prices a shade better.