With rates going up, refinance volume quickly heading south and originators looking for the next shiny thing, we are bound to see movement in the industry. That means mergers, buyouts and some companies closing. Migrating originators can be a tricky challenge for the next employer. There are two issues that may surface; who owns the customer and how were the originators compensated? I’ll save the former for another time. Last week I received a call …
Real estate transactions are the easiest way to launder money due to the size of the transactions and the amount of money that can be “cleaned”. All financial institutions are required to comply with the Bank Secrecy Act. Money laundering may also involve tax fraud as well as other potential crimes. All “financial institutions” must comply. According to the Bank Secrecy Act, a “financial institution” includes an exhaustive list of entities, including but not limited to: …
My analogy to guidelines these days is they are like trying to hold jello in the palm of your hand. Squishy, slippery, moving; slipping through your fingers! Patience is a virtue! We need to understand that underwriters spend MUCH more time determining the amount of income that can be used for qualifying, how consistent it is or will be, the job status of employees, viability of employer’s business and documenting the file to meet secondary …
Recently a mortgage loan originator in another state contacted me for help. He was stuck with an underwriter and was challenged by how to calculate the self employment income. In that conversation he told me how helpful it would be to originators to have a “loan advisor” to consult with. He encouraged me to set up Advisory Sessions and they are now available to any originator who knows the value of time. In addition to …
The Nationwide Multi-state Licensing System and Registry just posted an update on MLO testing. Here is the list of NMLS test centers opening as of May 1, 2020. The announcement went on to state alternative testing options: Starting in mid-May, SAFE MLO National Test candidates will also have the option to take the test via remote proctoring. More details will be provided soon. Once remote proctoring begins, test candidates will continue to have the option …
April 29, 2020 – The CFPB issued an Interpretive Rule today titled: Application of Certain Provisions in the TILA-RESPA Integrated Disclosure Rule and Regulation Z Right of Rescission Rules in Light of the COVID-19 Pandemic. The rule allows for COVID-19 to be a “financial emergency reason for borrowers to WAIVE the TRID closing waiting period and the three-day right of rescission. “The Bureau understands that the COVID-19 pandemic could pose temporary business disruptions and challenges …
26,000,000 people filed for unemployment in the past several weeks; and it’s not over! The Coronavirus is causing serious financial issues for states. For the first time ever, independent contractors are eligible under the CARES Act , even though unemployment taxes may not have been paid in. When the states start looking at all the workers who were 1099, what action will they take? The IRS is just as interested in independent contractors, even more …
Learn how to get YOUR Tripod. Free LIVE Webinar on May 5th 12:00 Noon ET! In this COVID-19 world, companies need all possible resources at their fingertips to keep businesses going and growing to recruit and provide quality professional development in a safe environment. Is consumer direct the future of mortgage origination with all the hidden pitfalls? While it may be a smart strategy for banks and credit unions to grow market share, retain servicing …
Every customer should receive a written analysis; it helps take emotion out of the equation. I do it for all my purchases and refinances. Yes, we have lots of long discussions, but hearing and seeing are two different things! The point of an analysis (particulary for refinances) is for a consumer to know the interest costs and principal reduction between a new loan and the original loan at it’s current balance. (you may need to …
Is there any good news today? I guess at least people who have filed will begin collecting some income. The mortgage world is in flux and the challenges are coming faster than we can deal with. We play a very important role as mortgage professionals by helping people make the right decisions; what’s in their best interests. This week I told three customers NOT to refinance. If you are submitting 100% of approvable files you …