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Debra Killian
June 1, 2020

Fannie Requiring Business Accounts for Self-Employed!

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...

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Debra Killian
November 26, 2018

Will You Be Ready for Transitional MLOS?

November 24, 2019 – That’s not a typo, yes, it’s one year away! Did you know federal law mandates states implement “transitional licensing authority” by November 24, 2019?  If you manage originators in a depository, have you considered if this will impact you and if so how?  How about...

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Debra Killian
July 17, 2023

Is Anti-Money Laundering (AML) Mandatory Compliance Coming for Realtors?

Do you know how money is actually laundered through real estate transactions?  Do you know your Anti-Money Laundering (AML) Training Requirements? Between 2015 and 2020, at least $2.3 billion was laundered through US real estate, with estimates by Washington, D.C. think tank Global Financial Integrity (GFI),  putting the number...

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Debra Killian
May 27, 2022

UDAAP-ECOA-TILA Are You Ready for Examiners?

The overlap between federal and state laws and regulations becomes very apparent once there is an examination and/or an enforcement action. With COVID dominating our work environment over the past two years, not many audits or exams were scheduled by state regulators.  That is all about to change.  They...

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Debra Killian
November 2, 2020

Real Estate Update November 2020

Don’t Try to Outsmart the Markets Getting ready to refinance your mortgage but waiting for rates to fall just one more time? Is that extra 1/8th percent ready to drop? Some consumers begin to follow economic news and perform no shortage of due diligence trying to pick the perfect...

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Don DeRespinis
February 26, 2019

CLOES.online AML Program answers FinCEN challenge for Innovative Approach to AML Compliance – Expanding Requirements Under the CDD Rule and Mortgage Originators

FINRA Regulatory Notice 18-19 issued May 11, 2018 expands AML Program requirements to include additional risk-based procedures, or the “fifth pillar” required for AML programs under the new FinCEN CDD Ruling Since all AML programs are customized based upon the size and risk of a Mortgage Lender, Broker or...

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Debra Killian
July 11, 2022

Mortgage Company Compliance Requirements for AML Training

How does a mortgage company meet the statutory requirement for Anti-Money Laundering education? The question comes up because many companies do not comply with the annual education requirement for all employees. In our opinion the law and regulations on AML training is purposely not specific because the term education...

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Don DeRespinis
January 24, 2018

Deb Killian, CRMS, presents CLOES.ONLINE at Mortgage Bankers Association Independent Mortgage Bankers Conference in Amelia Island, FL on January 23, 2018

Education of Loan Originators was a hot topic at the conference. Check out cloes.online

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Debra Killian
March 26, 2020

Jobless Claims at 3.2 MILLION Today! 9 Things Every Originator Should Be Doing

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...

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Debra Killian
March 17, 2020

Originators: Consumers Need You More Than Ever!

Loan locked, Loan Estimate out, Intent to Proceed signed, appraisal inspection scheduled for today. What could go wrong? And then the call…customer letting me know she canceled the inspection.  No, she didn’t want 0.00% 30 year fixed! She and her husband are both physicians working in an E.R. where...

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What People Say

How real people felt about CLOES.online

Gedne Gosselin

The instructor was very knowledgeable and applied examples in every possible scenario, making the material easy to understand.

 

2018 CE Product

Student CE Class 2018

8 Hour SAFE Comprehensive Federal CE 2018 – November 2018

Deb was great in presenting the true nature of the course piece by piece and helped with her many years of experience outline some of the more critical areas of the industry and expectations. The course was excellent because the provider was an experienced mortgage veteran for many years and understands how to present the material to make sure the key points as well as the main facts of the true nature of the job are outlined while instilling the required knowledge of the federal laws and guidelines mandated in the industry.