AI RESHAPING CREDIT ACCESS CONTINUED FROM PREVIOUS PAGE
lending to businesses in this industry? You should. It is enlightening (no pun intended). There are approximately 35 states allowing medicinal usage and another 15 states allowing recreational usage. The incoming VP has opined that they will consider decriminalizing marijuana usage and expunge the records of those individuals convicted of illegal marijuana activity. If this happens, how will these changes impact your hiring practices? Your background check procedures? Your lending documentation and ability-torepay requirement? The Safe Banking Act may open the door to permit mainstream banking of marijuana business too. Many, many years ago we had a customer shove thousands of dollars through the tiny little deposit slot on the ATM machine on a Saturday night. When the bank branch opened on Monday morning, it wreaked of
marijuana and we had to call the local police. They confiscated the deposited funds and paid a visit to the customer who made that deposit. It took months for the smell to go away and the customer jokes were plenty with the favorite being we did not provide enough donuts. We still do not know how he was able to force that thick envelope through the tiny slot. On the agenda for 2021 is a set of uniform settlement agent closing instructions. Face it, we need this. Right now, a set of lenders instructions to a settlement agent ranges from a few pages to 20-plus pages. TRID modified our delivery of these instructions from a few days prior to consummation to the date and possibly hours prior to consummation. If the transaction is a purchase transaction, the settlement agent may be new to the lender and not familiar with their closing package,
620 AS LOW AS
A down payment assistance program that offers your
FICO SCORE QUALIFY
borrowers $0 down on a home.
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42 MORTGAGE BANKER | JANUARY 2021
complicating the ability to comply with the instructions due to a lack of time to thoroughly read them. Defects are costly due to bad customer service, financial mistakes, buy-backs, or nonsaleable loans, etc. Non-compliance is costly too. When was the last time compliance professionals read through a completed set of lender’s instructions your company uses? The industry tried to establish uniform instructions many years ago without success. I hope these get through the process and it seems to have a lot of backing. Servicing issues will be prominent through 2021, especially if COVID persists. On December 7, 2020, the CFPB, a multistate group of state attorney generals, and bank regulators filed a complaint against a major servicing entity alleging multiple consumer financial law violations relative to the servicing of loans.
