Mortgage Banker Magazine November 2020

THE

BANKER

Covering the Entire Mortgage Lending Process and Everything In Between

MAGAZINE

November 2020

A BANNER YEAR FOR VA LENDING Jeffrey London Reviews a Record-Setting 2020

Eliminating the Unknowns from VA Loans pg. 32

How VA Lending has Changed pg. 36

Published monthly by Twelve 11 Publishing, LLC 9720 Royal Lamb Drive Las Vegas, NV 89145 Phone: 512.879.4363 Email: INFO@MORTGAGEBANKERMAG.com www.TheMORTGAGEBANKERMagazine.com SUBSCRIPTIONS This publication is for the benefit of mortgage banking professionals involved in all phases of the residential mortgage industry. If you are a mortgage banking industry professional and you do not currently receive The MORTGAGE BANKER Magazine, please go to www.themortgagebankermagazine.com and subscribe for FREE. The MORTGAGE BANKER Magazine is a digital monthly magazine that is sent directly to professionals' computers and hand-held devices. The subscription is FREE to all mortgage banking industry professionals. For additional copies for your colleagues and co-workers, please visit our website at www. themortgagebankermagazine.com and complete the online subscription form.

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November 2020

FEATURES

8 A Banner Year Jeffrey London Reviews a Record-Setting 2020 for VA Lending In all, 2020 has been a banner year for VA guaranteed loans. With the fiscal year that ended September 30, VA is coming off of its best year ever for the loan guaranty program, according to Jeffrey London, MPA, the executive director of VA’s Loan Guaranty Service.

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Eliminating the Unknowns from VA Loans

What Can You Do to Ramp Up Your Mortgage Marketing?

These are challenging times in America and around the world.

The COVID-19 pandemic has turned the world sideways, processes have changed, people have changed, and technology has evolved to meet new demands. In the mortgage world, rates plummeting to new lows have created a high-volume originations environment with refi’s and purchase deals both running at historic high lev-els.

When the coronavirus pandemic hit, mortgage lenders had to act fast. They needed to quickly digitize as many activities as possible to enable a “socially distanced” mortgage process. In response, many lenders raced to implement digitized process steps such as remote online notarization (RON). But tools such as RON are only part of the answer. And applications implemented piecemeal aren’t effective in the long term.

Earlier this year, the VA loan limit cap was removed, which now allows our veterans and active duty servicemembers to finance a home or to any purchase price they would like so long as they qualify by way of credit score and income. But I still think that there's a lot of originators out there that don't understand, and aren't aware that this still exists.

Like any other market, the mortgage market is subject to changes in supply and demand.

As soon as we get a hint of where supply and demand are going, we better understand where the market itself may be headed. Many people were predicting 2020 would be a major year for the mortgage market. The problem?

COVID-19.

AN INTERVIEW WITH JIMMY VERCELLINO

LUKE SHANKULA

GABE MINTON

BRIAN MADOCKS

Securing the Forbearance and Loan Modification Process Through Digitization

Simplifying the Digital Imperative for Mortgage Lenders

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Special

SECTIONS COMPLIANCE

REGULATORS AND AGENCIES

12

The CFPB’s Sweep of Investigations Related to VAGuaranteed Mortgage Advertisements

TROY GARRIS

Making Hay While the Sun is Shining AN INTERVIEW WITH RICK SHARGA

TECHNOLOGY

28

Beyond the Point-ofSale: Benefits of an End-to-End Digital Mortgage in a PostPandemic World PARVESH SAHI

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45

From the Desk of the Om-Bobs-man

FELECIA BOWERS

BOB NIEMI

50

The Mortgage Counselors

MITCH KIDER AND MICHAEL KIEVAL

THE C-SUITE

54

PROFILE: Wes Hunt

56

PROFILE: Tanya Brennan

FOUNDER AND PRESIDENT HOMESTAR FINANCIAL

MANAGING PARTNER AND PRESIDENT PHOENIXTEAM

DEPARTMENTS 38

How VA Lending Has Changed AN INTERVIEW WITH MICHAEL “MO” OURSLER

Why Housing Market Potential Remains High MARK FLEMING

The Importance of a Robust CMS Structure

Monthly

LOAN ORIGINATION

36

42

LEGAL

CAPITAL MARKETS

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12

6 From the Editor

52 Mortgage Banking Lawyers 58 MBA Education & Training Calendar

59 60 62 63

White Papers & Webinars Data Download Business Services Directory Sponsors Corner

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THE

BANKER

MAGAZINE

Our Mission The MORTGAGE BANKER Magazine is dedicated to providing quality informational/educational content that betters the mortgage process at every step. The content is oriented to help professionals progress their understanding of the residential mortgage banking business and develop their skills at improving the efficiency and profitability at all levels.

PUBLISHER Ben Slayton BSlayton@twelve11media.com MANAGING EDITOR Brian Honea Brian@twelve11media.com SENIOR EDITOR Jill Emerson Jill@twelve11media.com OPERATIONS DIRECTOR Dawn Slayton Dawn@twelve11media.com ADVERTISING David Hoierman David@twelve11media.com PRODUCTION Henry Suchman Henry@twelve11media.com

FROM THE EDITOR Our veterans put their lives on the line every day to protect our freedoms, and one of the ways the government is giving back to them is by making it easier for them to obtain a mortgage loan. Looser regulations combined with historically low rates have resulted in a recent boom in loan volume to veterans.

To coincide with the month in which we celebrate Veteran’s Day, we have dedicated this issue to discussing VA loans and lending. Our cover feature is an exclusive interview with Jeffrey London, Executive Director, Loan Guaranty Service with the U.S. Department of Veterans Affairs, discussing options for lenders and servicers when their VA loan customers cannot pay. Then we have Jimmy Vercellino, branch manager with Goldwater Bank in Phoenix and a former Marine who has made mortgage loans to veterans his life’s work, talking about unknowns where VA lending is concerned and what mortgage industry professionals can do to educate their peers in that area. And Michael “Mo” Oursler, Chief Operating Officer with VA fintech lender NewDay USA, covers some of the recent regulatory changes concerning VA lending.

What challenges are you facing with your VA lending and how are you handling those challenges? We want to hear about your experiences.

We are always listening. You can always drop us a line via the email address below.

DIGITAL MEDIA Lucas Luna LLuna@twelve11media.com COLUMNISTS & CONTRIBUTING AUTHORS Felecia Bowers Mark Fleming Troy Garris Mitch Kider Michael Kieval

Brian Madocks Gabe Minton Bob Niemi Parvesh Sahi Luke Shankula

The MORTGAGE BANKER Magazine is the official publication of the Mortgage Compliance Professionals Association of America.

Brian Honea Managing Editor Editor@MortgageBankerMag.com The MORTGAGE BANKER Magazine welcomes your feedback.

If you have comments, questions, criticisms, praise, or information to share with us and our readers, please write us at Editor@MortgageBankerMag.com.

November 2020

AUTHORS

Felecia Bowers

Mark Fleming

Troy Garris

Brian Madocks

Felecia Bowers has spent more than 40 years as a bank examiner and chief compliance officer, working specifically with mortgage bankers for over 35 years. Her experience is complemented by the fact that while she was the CCO, she ran the secondary/ capital markets department, quality control, and HR, and she is a DE Underwriter.

Mark Fleming serves as the chief economist for First American Financial Corporation, a leading provider of title insurance, settlement services and risk solutions for real estate transactions that traces its heritage back to 1889. In his role, he leads an economics team responsible for analysis, commentary and forecasting trends in the real estate and mortgage markets.

Troy Garris is Co-Managing Partner of Garris Horn LLP. Troy deals with enforcement defense, federal and state compliance, company formation, and mergers and acquisitions. Troy’s clients are independent mortgage bankers, banks, homebuilders, and related entities. Troy is also a YouTuber, hosting Troy at Garris Horn, the Mortgage Banking LiveStream.

Brian Madocks is the chief executive officer of eOriginal, the leading platform for creating, managing, and monetizing trusted digital loans. With more than 25 years of experience in business technology and application software solutions, Brian has served as CEO of Revitas, Inc., Vitalyst, Inc. and SunGard Higher Education, as well as senior vice president and general manager of SAP America.

Gabe Minton Gabe Minton is executive vice president and chief information officer at Mortgage Connect where he provides leadership and vision for the technology and information strategy, including the development of next generation digital platforms to facilitate a seamless experience between the consumer and lender and to maximize operational efficiencies.

Parvesh Sahi

Luke Shankula

Parvesh Sahi, the Senior Vice President of Business Development with Ellie Mae, part of ICE Mortgage Technology, is responsible for the corporate strategy development of partner, investor, and government relations. His focus on technology, secondary market partner relationships, and connectivity has streamlined the mortgage origination process and experience for customers and partners.

Luke Shankula is a devoted husband and father to two children and is a leading seven-figure mortgage marketing expert and the CEO of Paragon Digital Marketing. Luke’s biggest wish is to transform lives and businesses in a positive way and become a role-model for the future generation.

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November 2020

Regulators and Agencies

A The Digital BANNER Difference is Being YEAR

SMART

Jeffrey London, VA’s Executive Director, Loan Guaranty Service, Reviews a Record-Setting 2020

By Paul Anselmo, Evolve Mortgage Services

By Brian Honea

Through all the uncertainty that the year 2020 has presented to us, one thing is certain: COVID-19 has not slowed VA lending at all. Not only has it not slowed it down, loans are being guaranteed by the U.S. Department of Veterans Affairs in record numbers.

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All of this means that more of our country’s servicemen and women are utilizing the benefits that VA is offering to them.

More and more members of our military are obtaining mortgage loans, which means they are achieving homeownership with the government’s help.

Not only that, but VA’s loss mitigation programs are helping veterans that can’t make their mortgage payments due to COVID-19 stay in their homes and avoid foreclosure.

In all, 2020 has been a banner year for VA guaranteed loans.

With the fiscal year that ended September 30, VA is coming off of its best year ever for the loan guaranty program, according to Jeffrey London, MPA, the executive director of VA’s Loan Guaranty Service. “We guaranteed over 1.2 million loans, and that's the program record, “London said. “The previous program record was in 2017 where we guaranteed 740,000 loans, a 62 percent increase. But what I'm most proud about those 1.2 million loans is we also had record volume for purchase loans. We guaranteed a little over 428,000 purchase homes so veterans and service members were not only able to utilize their benefits to refinance loans, they also used the benefit to purchase homes. We're extremely proud of those numbers.”

To put those numbers into perspective, those 1.2 million loans represent about $375 billion in loan volume, and the 428,000 purchase loans make up about $130 billion of that.

“We've leaned in and really had flexible processes and policies to enable our veterans and service members to utilize their earned benefit,” London said. “I'm also proud of the fact that over the years, including this past year, we implemented our

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process improvements to make it even easier for veterans to utilize the benefit and for lenders to work with us.”

As an example of VA’s more flexible policies working to make it easier for veterans to obtain a mortgage, London said out of the two million requests they had received for eligibility determination, 75 percent of them were determined automatically without human intervention, whether requested by the lender or the veteran himself or herself. And even out of the requests that VA had to touch, 85 percent determined eligibility within one day and all of them were determined within five days.

Not only that, but VA has streamlined the appraisal process to where the majority of appraisal requests made by lenders are approved instantaneously and the assignments are completed within the timely standards VA has set.

“One of the things that we're really proud of is the fact that to add on to our process improvements, we also are embarking on many technological advances,” London stated. “We've been awarded a new information technology contract this year where we're going to implement the safe methodology and really focus on product management to improve our systems and processes.”

Also assisting veterans with getting mortgages is the Blue Water Navy Act, which took effect on January 1, 2020, and effectively eliminated the FHFA’s conforming loan limits, which were raised to $510,400 this year. This provision allows veterans and service members to obtain a VA guaranteed loan for any amount, even above the conforming loan limit. That, along with the no down payment option, has not only helped veterans obtain mortgage loans in

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November 2020

Regulators and Agencies high cost areas, but also “beyond the high cost areas, we're really making sure that veterans can choose to live wherever they choose to live and whatever type of loan they want to purchase. As long as they qualify, they can utilize their VA home loan benefit to do so,” according to London.

The main driver of the record-setting 2020 for VA loan guaranty department is rates. Historically, low interest rates are pushing veterans into the market place to purchase homes as well as providing an incentive for service members who already own homes to refinance their loans to lower their monthly payments and the amount they pay out over the life of their loan. Not only that, London said, but many veterans have been able to tap into their personal equity in order to take care of personal needs.

Yet, another driver of this year’s VA loan boom is that VA’s loan product has been priced lower than conventional and FHA loans for the last five years. Low closing costs are another driver; and, since 80 percent of VA guaranteed loans are the no down payment variety, the requirement for private mortgage insurance is eliminated, which alone makes for a combined savings of approximately $73 billion over the life of those loans, according to London.

“If you take all of those factors together about the buying power that veterans and service members have, along with the process improvements that we have made, we’ve made it easy for lenders to partner with VA to close those homes,” London said.

“Because, as you know, we've delegated authority to the industry to close loans on behalf of VA.” Another factor that has come into play during 2020, largely due to the COVID-19 pandemic that has resulted in the loss of income for many, is protecting veterans

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from losing their homes in the event that they can’t make their monthly mortgage payments.

VA has those loans covered with a “host of options and activities” for loss mitigation, according to London. When veterans face financial difficulties, VA has a dedicated team that assigns a loan technician to the veteran whose loan is in default to intervene on that veteran’s behalf and work directly with the loan servicer. And that technician’s job includes oversight of the loan servicer to make sure that everything possible is being done to cure the default and avoid foreclosure.

“Just last year alone, we helped over 85 percent of veterans whose loans were in default to avoid foreclosure,” London said.

“We pay incentives to servicers for the loss mitigation options that are available. We have our traditional repayment plans, we have a suite of loan modification programs that veterans can take advantage of, and certainly during the national emergency, we've leaned in and made it much easier for servicers to help those veterans who are in financial distress.”

And one of the things VA has done to make it easier recently is relaxing regulatory requirements to defer missed mortgage payments until the end of a mortgage loan, so that when veterans get back on their feet, they “do not have to worry about paying any missed payments right away.”

With 2020 having been a record-setting year for VA as far as mortgage loans in the midst of a pandemic, it will be interesting to if the pace continues in 2021. MBM Brian Honea is the managing editor of The MORTGAGE BANKER Magazine.

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November 2020

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TO BED

Regulators and Agencies

THE CFPB’S SWEEP OF INVESTIGATIONS RELATED TO VA-GUARANTEED MORTGAGE ADVERTISEMENTS

By Troy Garris, Garris Horn LLP

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n September 19, 2020, the Consumer Financial Protections Bureau (CFPB) published a press release citing a newly issued consent order to a mortgage broker/lender, the eighth delivered by the Bureau in under two months related to deceptive loan advertisements sent to servicemembers and veterans. The series of investigations is in response to concerns about potentially unlawful advertising in the market that the VA identified.

In each instance, the principal means of advertising VA-guaranteed loans is through direct-mail advertisements sent primarily to United States military servicemembers and veterans. The Bureau found that these companies mailed consumers advertisements for VA-guaranteed mortgages that contained false, misleading, and inaccurate statements or lacked required disclosures, in violation of the Consumer Financial Protection Act’s (CFPA) prohibition against deceptive acts and practices, the Mortgage Acts and Practices – Advertising Rule (MAP Rule), and Regulation Z. The consent orders require the companies to pay civil money penalties and impose requirements to prevent future violations, such as “bolster their compliance functions by designating an advertising compliance official who must review their mortgage advertisements for compliance

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with mortgage advertising laws prior to their use; prohibiting misrepresentations similar to those identified by the Bureau; and requiring the companies to comply with certain enhanced disclosure requirements to prevent them from making future misrepresentations.”

Further details regarding the eight actions are as follows, including civil money penalties:

JULY 24, 2020: CA LICENSED MORTGAGE BROKER/LENDER $460,000 • Advertisements misrepresented the credit terms of the advertised mortgage loan by stating credit terms that the company was not actually prepared to offer to the consumer.

• Advertisements misleadingly described an advertised introductory interest rate as a “fixed” rate, when in fact the rate was adjustable and could increase over time.

• Advertisements created the false impression that they were affiliated with the government by using words, phrases, images, or designs that are associated with the VA or the Internal Revenue Service.

• Advertisements used the name of the consumer’s lender in a misleading way by not adequately disclosing their own names

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and the fact that they were not associated with, or acting on behalf of, the consumer’s current lender, as required by Regulation Z.

actually prepared to offer to the consumer.

• Advertisements misleadingly described an advertised introductory interest rate as a “fixed” rate, when in fact the rate was adjustable and could increase over time.

• The company made false claims about consumers’ existing loans, and falsely implied that consumers could address these problems by obtaining a loan from the company.

• Advertisements created the false impression that they were affiliated with the government by using words, phrases, images, or designs that are associated with the VA or the Internal Revenue Service.

• Advertisements failed to properly disclose, when required by Regulation Z, credit terms for the advertised mortgage, such as the consumer’s repayment obligations over the full term of the loan and the period during which certain interest rates would apply.

JULY 24, 2020: CA LICENSED MORTGAGE BROKER/LENDER $645,000

• Advertisements used the name of the consumer’s lender in a misleading way by not adequately disclosing their own names and the fact that they were not associated with, or acting on behalf of, the consumer’s current lender, as required by Regulation Z.

• Advertisements misrepresented the credit terms of the advertised mortgage loan by stating credit terms that the company was not

• Advertisements also failed to properly disclose, when required by Regulation Z, credit terms for the advertised mortgage, such as the

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November 2020

Regulators and Agencies consumer’s repayment obligations over the full term of the loan and the period during which certain interest rates would apply.

• Advertisements failed to properly disclose, when required by Regulation Z, credit terms for the advertised mortgage, such as the consumer’s repayment obligations over the full term of the loan.

• Advertisements created the false impression that they contained a property assessment as well as misleading comparisons between hypothetical credit terms and the terms of the advertised product.

AUGUST 26, 2020: CA LICENSED MORTGAGE BROKER/LENDER $260,000 • Advertisements misrepresented the credit terms of the advertised mortgage loan by stating credit terms that the company was not actually prepared to offer to the consumer, including misrepresenting the payment amount applicable to the advertised mortgage and the nature or amount of cash available to the consumer in connection with the advertised mortgage.

AUGUST 21, 2020: CA LICENSED MORTGAGE BROKER/LENDER $150,000 • Advertisements misrepresented the credit terms of the advertised mortgage loan by stating credit terms that the company was not actually prepared to offer to the consumer, including advertising a lower annual percentage rate than it was prepared to offer.

• The company made misrepresentations about the existence and amount of fees or costs to the consumer in connection with the advertised mortgage.

• The company made misrepresentations about the applicable fees in connection with the advertised mortgage.

• Advertisements failed to properly disclose, when required by Regulation Z, credit terms for the advertised mortgage, such as the consumer’s repayment obligations over the full term of the loan.

• Advertisements misleadingly described variable-rate loans as “fixed” rate loans, when in fact the rate was adjustable and could increase over time.

• Advertisements falsely stated or implied that an appraisal, assets, and income documentation were not required to qualify for certain loans and that consumers with FICO scores as low as 500 would qualify for the advertised rates.

SEPTEMBER 1, 2020: FL LICENSED MORTGAGE BROKER $50,000 • The company advertised specific credit terms, such as interest rates, APRs, and hypothetical payment amounts that it was not prepared to offer, or that it could only offer for an introductory period but advertised as if they were permanent loan terms.

• Advertisements falsely represented that it had records showing that the value of the consumer’s property had increased over the past year by a specific percentage.

• Advertisements also used phrasing and formatting that falsely represented or implied that the company was affiliated with the government, including the VA, that the advertised product was endorsed, sponsored by, or affiliated with the United States government, or that the United

• Advertisements created the false impression that the company was affiliated with the government by using words, phrases, images, or design characteristics that are associated with the VA or the Internal Revenue Service.

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States government was the source of the advertisements.

• In advertisements mailed between June 2016 and January 2019, the company stated that it would pay an estimated escrow refund of a specific amount if the consumer refinanced through the company, even though the advertised escrow refund amount was calculated using a method that would not yield an actual estimate for that consumer, and customers were required to fund escrow accounts upon generating a new loan.

SEPTEMBER 1, 2020: MD LICENSED MORTGAGE BROKER $230,000 • The company advertised specific credit terms, such as APRs and hypothetical payment amounts, that it was not prepared to offer, or that it could only offer for an introductory period but advertised as if they were permanent loan terms.

• Advertisements falsely stated: “the Economic Stimulus Program will end soon. There is currently no plan to extend the Stimulus Program.”

• The company used terms in millions of its advertisements that falsely represented or implied that the company was affiliated with the government, including the VA, that the advertised product was endorsed, sponsored by, or affiliated with the United States government, or that the United States government was the source of the advertisements.

• Advertisements included claims or terms that require additional disclosures, but the company failed to make these disclosures.

• In advertisements mailed between April 2016 and May 2017, the company stated that it would pay an estimated escrow

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Regulators and Agencies refund of a specific amount if the consumer refinanced through the company, even though the advertised escrow refund amount was calculated using a method that would not yield an actual estimate for that consumer, and in cash-out transactions the “refund” was actually added to the principal of the consumer’s loan.

• The company sent advertisements between December 2015 and April 2017 representing that a consumer could “[s]kip two payments” or “miss” two payments by refinancing with the company, but it did not disclose the limitations on this option, or that the skipped or missed payments would be added to the principal balance of the consumer’s loan.

• Advertisements stated: “the Economic Stimulus Program will end soon. There is currently no plan to extend the Stimulus Program,” which was untrue.

• Advertisements included claims or terms that require additional disclosures, but the company failed to make these disclosures.

SEPTEMBER 2, 2020: DE LICENSED MORTGAGE BROKER/LENDER $225,000 • Advertisements misrepresented the credit terms of the advertised mortgage loan by stating credit terms that the company was not actually prepared to offer to the consumer, including misrepresenting the interest rate or payment amount applicable to the advertised mortgage and the nature or amount of cash available to the consumer in connection with the advertised mortgage.

• Advertisements falsely represented that the consumer’s access to mortgage-refinance benefits through VA-guaranteed loans was time-limited.

• Advertisements failed to properly disclose, when required by Regulation Z, credit terms for the advertised mortgage, such as the annual percentage rate of the advertised mortgage or the consumer’s repayment obligations over the full term of the loan.

SEPTEMBER 14, 2020: CA LICENSED MORTGAGE BROKER/LENDER $625,000 • Advertisements misrepresented the credit terms of the advertised mortgage loan by stating credit terms that the company was not actually prepared to offer to the consumer, including misrepresenting the annual percentage rate applicable to the advertised mortgage.

• The company misleadingly advertised rates or payments as fixed, even though the advertised mortgage was an adjustable-rate mortgage or the payment was not fixed for the indicated duration.

• The company misrepresented the existence, nature, or amount of cash or credit available to the consumer, and the existence or amount of fees or costs to the consumer, in connection with the advertised mortgage.

• Advertisements created the false impression that the company was affiliated with the VA.

• The company made misrepresentations about the existence or amount of fees or costs to the consumer in connection with the advertised mortgage.

• Advertisements failed to properly disclose, when required by Regulation Z, credit terms for the advertised mortgage, such as the number and time period of payments associated with the consumer’s repayment obligations over the full term of the loan.

• Advertisements created the false impression that the company was affiliated with the government by using words, phrases, images, or designs that are associated with the VA, Internal Revenue Service, or Federal Deposit Insurance Corporation.

• Advertisements used the name of the consumer’s lender in a misleading way by not adequately disclosing the company’s name and the fact that it was not associated with, or acting on behalf of, the consumer’s current lender, as required by Regulation Z. MBM

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they share the information with, and for what purpose. The Vetted VA Go Bag puts Veterans in control of their financial information.

The custom branded financial super-app provides Veterans with tools that include: • Credit report, credit score, credit monitoring, and alerts • Financial tools that enable spending analysis, budgeting, goal setting, and tracking • Access to an extensive library of homeownership and finance education •

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by FinLocker is a secure app where Veterans can safely store their financial data from other financial institutions.

The app is built around the concept of consumer-permissioned data, so no financial institution will ever see a Veteran’s financial records until they give permission and share with a specific Vetted Professional. The Veteran has full control of what they store in the Vetted VA Go Bag, who

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Vetted VA is an online community where Veterans can ask real estate and mortgage questions and receive answers from a network of Vetted Financial Professionals without being solicited. Vetted VA founder, Christopher Griffith was seeking additional financial tools to assist Veterans in achieving their financial goals.

FinLocker was identified as a partner to deliver Veterans new financial health and wellness tools with its custom-branded financial super-app that focuses on all aspects of the homeownership journey. In March 2020, Vetted VA partnered with FinLocker to deploy the Vetted VA Go Bag, the financial planning and monitoring tool for Veterans.

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Veterans have lacked a comprehensive financial preparedness solution, especially one focused on real estate finance. This is made painfully clear once many leave active service and are no longer supported, instead they are seen as a specialized market that are easy to target and solicit. This solicitation tends to prey on their status as a Veteran by offering specialized services and programs which do not actually provide anything of lasting financial value to the Veteran. The common issue is a lack of understanding and transparency throughout.

“Prior proper planning prevents piss-poor performance,” says Christopher Griffith, Marine Veteran and Founder of Vetted VA. “Both active duty and discharged Veterans understand this saying. With debt specifically, those who cannot plan for the debt they will accrue end up only saving a little money and relying on hope. This isn’t the military way - yet it has been the standard until now.”

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Uploading financial documents they will need when they are ready to proceed with their real estate transaction

• Direct connection to the Vetted VA Professionals network for financial advice Partnering this tool with professional oversight and counseling from Vetted VA Professionals means the Veteran is not only prepared before the conversation, but they have a safe and secure place to take action based on the consultation and, when ready, can take action to share their documents to the Vetted Professional to move the process forward.

Vetted VA focuses on keeping the Veteran in control of their financial future by providing freedom from solicitation, liberty of knowledge from trusted sources, and accountability to deliver what is promised through vetting. FinLocker has fulfilled its part of that vision by supporting the liberty and accountability of information.

Capital Markets

MAKING HAY WHILE THE SUN IS SHINING

Many lenders are seizing the opportunity to go public.

What does this mean for the market?

An Interview with Rick Sharga, Executive Vice President at RealtyTrac

By Brian Honea

The last few months have seen a number of the country’s largest privately-held lenders take advantage of near record origination volumes and near record low interest rates by going public.

Rocket Companies, the parent organization of THE biggest lender, Quicken Loans, began the trend in early August when it raised about $1.8 billion in its IPO; and, it didn’t take long for others to follow suit. In late September, the largest wholesale lender in the U.S., United Wholesale Mortgage, announced its intention to go public via a merger with Gores Holdings IV with a transaction value of $16.1 billion, making it the largest special purpose acquisition company transaction to date. Also in September, it was reported that LoanDepot is mulling an IPO with a valuation that could be worth up to $15 billion, after scrapping one at the last minute in 2015. Texas-based Caliber Home Loans filed for its IPO in early October that could be worth up to $2 billion. Two smaller Texas-based lenders, Guild Mortgage and AmeriHome Mortgage, have also jumped into the IPO ring in the last month or so.

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What does all of this mean for the market and what does the future hold for these companies that have all gone public in the last two to three months? One of the nation’s top mortgage analysts, Rick Sharga, executive vice president at RealtyTrac, recently addressed these and other questions during a chat with The MORTGAGE BANKER Magazine.

in their system. I think those technology platforms make these lenders attractive to the people who are investing in fintech. One of the questions I’ve had people ask me is, “Why would an investor be interested in taking somebody like this to market at the peak of the market knowing that origination volume is likely to slow down at some point?” I think the technology platforms that these players all have is one of those reasons.

The rationale being those are the kinds of companies that will continue to succeed as the market cools off a little bit.

MBM: Why are all these lenders choosing to go public at this time?

Rick Sharga: The opportunity for these lenders to go public is kind of like the old saying about making hay while the sun is shining. We’re looking at a year that will probably set a record for mortgage originations because of all the refinance business that has been going on due to low interest rates and the unexpectedly strong return of purchase activity for both new homes and existing homes in spite of the pandemic. If you’re a lender participating in that business and had any inklings of doing a public offering, now is probably about the best time to get yourself into the market.

There also seems to be a healthier valuation of those types of companies by the capital markets. LoanDepot planned to go public a few years ago and then withdrew, and that was largely believed to be due to a tepid response from the capital markets in terms of valuation. It’s a combination of money being available in the capital markets, a healthier valuation for lenders, and the strength of the lending market in general.

MBM: Why did originations take off not long after the pandemic hit?

Rick Sharga: When the pandemic hit and the Fed announced it was going to a low interest rate model for the foreseeable future, the bond markets acted in concert. So, we had an unexpected drop in mortgage rates from what were already pretty close to historic lows, which fueled a lot of refinance activity and is one of the things driving purchase activity. That’s one thing that a lot of people probably weren’t expecting when the pandemic hit.

Also, the unemployment numbers have been very heavily skewed toward a number of industries such as travel, hospitality, tourism, retail, and restaurants. Those industries tend to be made up of hourly-wage employees who don’t make a lot of money, are relatively young, and probably don’t have a ton of formal education. All of those criteria tend to be geared toward more renters than homeowners. So, the unemployment numbers that have swelled so heavily during this pandemic have been disproportionately skewed toward renters rather than homeowners. Renters are not going to do a refi loan, and refinances are accounting for about two-thirds of the origination activity right now.

There could also possibly be a number of homeowners who aren’t sure what their financial situation might look like going forward who might have tapped into their current home equity either to get a refi to lower their monthly payments as a hedge, or might have done a limited cash out

MBM: Is there a common denominator for these lenders?

Rick Sharga: I think a differentiator in the marketplace right now is that the companies that are going public all seem to be independent or non-bank lenders and they all tend to have deployed some sort of technology platform as their business models. Quicken Loans has Rocket Mortgage, LoanDepot has spent an enormous amount of money on their digital platform, mello, and United Wholesale Mortgage has technology The MORTGAGE BANKER Magazine

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November 2020

Capital Markets refi to give themselves a cushion in the event that things do go sideways for them.

MBM: What is the long-term effect of all these IPOs on the market?

Rick Sharga: Long-term it gives these companies much better access to capital, because they think they can go back to the public markets and raise money that way. If you’re an independent mortgage banker or a non-bank mortgage lender, you’re always at a little bit of a disadvantage compared to depository institutions that can leverage those deposits when they need capital.

So, it does put some of those independent bankers and non-bank lenders, especially the bigger ones, on a more even playing field, from a capital standpoint, with the larger banks. I think that’s meaningful.

Also, it probably doesn’t hurt them from a reputational and branding standpoint among consumers who might view publicly traded companies as being safer or being more credible than privately held companies, especially with what we went through in the last boom and bust cycle when so many of those lenders disappeared.

MBM: Do you see more independent mortgage bankers and non-bank lenders going public while origination volumes are still high?

Rick Sharga: I wouldn’t be surprised. There are a lot of these companies that start out with the notion of either ultimately being acquired by a larger entity or going public, and the founders and shareholders have a vested interest in seeing that happen. When you get to a period where business growth and market opportunity intersect, that’s a double trigger that a lot of these organizations are going to want to take advantage of. I’d be surprised if we didn’t see more people throw their hat into the ring before this is all said and done. MBM Brian Honea is the managing editor of The MORTGAGE BANKER Magazine.

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Technology

Securing the Forbearance and Loan Modification Process Through Digitization

What is needed are very efficient, self-serve capable and secure digital solutions. This will enable borrowers to work out their situations remotely from the safety and comfort of their homes and get their mortgages back on track. It is no different than all of the rest of the eCommerce that is running remotely during this pandemic. It is more than an excellent portal; the user experience needs to be taken into consideration, and the more standardized integration that flows to and from the application, the better. This requires key integrations and touch points with a lender’s existing systems. Furthermore, by utilizing Single Sign On (SSO) technologies, if there is a handoff to a second system, the borrower does not know it and is still fully secured from their initial login to their bank or mortgage provider’s website.

Electronic signatures and records have come a long way, both over the last 20 years and over the last year since the pandemic, which has accelerated the need. Now eSign platforms are commonplace and accepted by the masses to be able to electronically sign basic documents. Many lenders are moving forward with hybrid eClose options where their consumers can eSign documents ahead of the closing and then wet-sign or remote online notarize (RON) documents that need notarization.

Innovative companies are implementing cascading “e” models to illustrate up front in the transaction “how e a borrower can be.” Given the subject property address and some other characteristics, can this property be eClosed? eRecorded? eNotarized? Based on the answers to those questions, lenders have the capability to accelerate new originations or loan modifications requiring notarization and recordation from weeks to days. There are further ways to accelerate the underwriting and title clearance processes to get the timelines even shorter. By using secure digital connections and storage and tamper-evident seals on documents, better security and integrity can be ensured throughout the transaction.

The good news is that a lot of these eProcesses can be used across both originations and servicing.

At the end of the day, an electronically signed document is just that, it doesn’t matter to the state

By Gabe Minton, Mortgage Connect

T

hese are challenging times in America and around the world. The COVID-19 pandemic has turned the world sideways, processes have changed, people have changed, and technology has evolved to meet new demands.

In the mortgage world, rates plummeting to new lows have created a high-volume originations environment with refi’s and purchase deals both running at historic high levels. The moratoriums have slowed the default, bankruptcy, and foreclosure parts of the process, but while that remains in a holding pattern, many consumers have been helped by the CARES Act by taking advantage of the forbearance provisions. Now is the time for workouts to occur, whether it is a deferral, a loan modification, paying back missed payments, or even nothing needed, the borrower kept paying their mortgage with the pandemic declaration, borrowers and lenders alike are keen on working solutions out and getting the payments back on track.

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or county what type of transaction it was. So being able to reuse the digital infrastructure across both business lines is key in a lender being able to utilize these new technologies while keeping costs down.

By incorporating knowledge-based authentication (KBA) into the solution, it identifies the parties to the transaction securely decreasing fraud risk.

By moving more of these processes fully digital and never involving any printout or paper during the entire process, integrity can be better ensured across the transaction. Better integrity of the eFiles that are used in the transaction is better security and makes it much more difficult for fraud to occur around the documents themselves. By using SSO, KBA, and other technologies, you can better identify the parties to the transaction, helping to ensure it is secure and there is no impersonation happening.

There are also vendors and solutions that are helping with wire fraud. By implementing additional checks that can be automated through application The MORTGAGE BANKER Magazine

programming interfaces (APIs), any time a wiring instruction is loaded into their system to be used in a closing, a lender can do a compliance check to confirm the integrity of the account listed and ownership, as an additional “belt and suspenders� to this critical process. These databases can also be called just prior to closing to double-check one last time. Of course, nothing beats educating your employees, borrowers, and trading partners to check and recheck any time there is an update or change to the critical wiring instructions.

This is a very exciting time in our industry, with a lot of needed growth in the digital arena. We are all lurching forward in the digital ecosystem that some of us have been working on for years.

This new ecosystem will allow for borrowers to be remote to the transaction and digitally transact from the comfort of their environment, which will drive amazing efficiencies and higher levels of security.

MBM

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Technology

Simplifying the Digital Imperative for Mortgage Lenders

By Brian Madocks, eOriginal

When the coronavirus pandemic hit, mortgage lenders had to act fast. They needed to quickly digitize as many activities as possible to enable a “socially distanced� mortgage process.

In response, many lenders raced to implement digitized process steps such as remote online notarization (RON).

But tools such as RON are The MORTGAGE BANKER Magazine

only part of the answer. And applications implemented piecemeal aren’t effective in the long term.

The answer? First, you need purpose-built, tightly integrated digital solutions.

But even more important, your organization must actively pursue digital adoption that powers every step of the endto-end mortgage process.

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FOUR STAGES OF MORTGAGE DIGITIZATION Digitization of mortgage lending involves much more than a buyer attaching an electronic signature to a closing document. True digitization extends across four key stages:

important goal, but it’s also crucial to approach your digital journey in a thoughtful way.

The key is choosing purpose-built solutions. As one example, an appellate court recently ruled that a plaintiff couldn’t show that a loan was compliant or enforceable because it failed to use a digital platform specifically designed for digital loan and asset management.

Another good example is RON. Many firms have moved fast to implement a RON solution. Digitized notarization makes a lot of sense. But what if the closing process involves a hybrid of in-person and remote steps? And which files do the lender or settlement agent need to present to the notary? All 30 documents typically involved in mortgage close or just those documents that actually need to be notarized?

Therefore, your digital mortgage solution needs to be purpose-built, and it needs to be implemented in a way that ensures the digital chain of custody and evidence from the first step. Speed matters, but compliance and certainty are forever.

1. Loan application – Customers digitally apply for a mortgage through online channels. The loan originator’s applications then score the borrower and make a judgment on approval in an automated manner.

2. Loan closing – The borrower, lender, and settlement agent digitally come together to execute the required documents.

3. Loan management – Loan assets are stored or transferred to a custodian with compliance certainty to meet all requirements as transferrable records.

4. Loan monetization – The mortgage is most often sold into the secondary market through Fannie Mae, Freddie Mac, or Ginnie Mae. Throughout these stages, legal and regulatory compliance are paramount. For example, when a loan is created, it must comply with governing laws such as the Uniform Electronic Transactions Act (UETA) and the E-Sign Act. It also needs to meet all safe harbor standards.

Likewise, a loan must be tamper-sealed to ensure it hasn’t been modified without authorization. And it requires an immutable and auditable digital chain of custody and evidence to show every action taken on the single, authoritative copy.

Fannie Mae, for example, demands that the originator create an authoritative copy. A digital loan isn’t static, which means you need to create a legally enforceable loan from the moment it’s signed all the way through its lifecycle. Enforceability means that if you own a loan, you can demonstrate:

THE DIGITIZED FUTURE OF MORTGAGE LENDING Pre-COVID-19, loan originators were focused on how digitization could optimize the borrower’s experience. But contactless close is no longer just a convenience; it’s an imperative.

Digitization can ensure the safety of all parties during closing. Early in the pandemic, there were stories of closings that involved people sitting in cars while the settlement agent walked from car to car with the transaction paperwork. That might have worked in April, but it’s certainly not going to work for a Boston winter. Not to mention, it’s not a longterm solution.

Just as important, digitization can provide for the safety of back-office workers. Many employees now work from home. In a paper-based process, the paperwork must be physically shuttled from place to place. A digitized process enables employees to manage every step from their remote locations.

Ultimately, your digital strategy must enable the short-term goal of contactless closings and the long-term goal of delivering exceptional customer experiences and operational efficiencies. The key is to leverage purpose-built solutions for best-in-class functionality and regulatory compliance, and achieve end-to-end digitization that optimizes every stage of the mortgage lending process. MBM

• The loan was created properly; • It wasn’t altered without permission; and • If there was an authorized alteration, it was properly documented and stored with a digital chain of custody and evidence.

SIMPLIFYING DIGITAL ADOPTION AND ACCELERATING LIQUIDITY In our new COVID-19 era, mortgage lenders want to achieve digital adoption quickly. That’s an The MORTGAGE BANKER Magazine

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ADVERTORIAL

THOUGHT LEADER The Emerging Role of Technology

Solving challenges faced in the mortgage industry is a driving force for many tech firms.

Historically the entire industry has been slow to adopt the technology we are now seeing implemented in the emerging digital mortgage experience.

A lot of factors are playing into that right now, be it regulatory compliance, cutting edge integrations of data exchanges, or COVID-19 and the push to a remote and touch-free process.

Advanced Data has always been an innovator when it comes to technology. Internally we make enhancements to our systems on a regular basis to improve the user experience.

With our customizable, proprietary software Advanced Data is able to accomplish significant developmental advancement without the common roadblocks.

Part of our technological success has been our dedication to strong partnerships with other innovators. Collaboration is key and strong partner relationships allow us to be a part of the

ongoing conversation. The end game is improving the entire mortgage experience. We’re at the table, making decisions that provide solutions to us, our clients and ultimately the consumer. Not only are we enhancing the digital mortgage experience overall but we’re a voice in shaping it. Our eVoE™ tool is on the top of that list. eVoE™, released in early 2018, proved to be a tool that both improved our internal processes and allowed us to deliver a digital verification that is 100% complete, legible, secure and reliable. Fraud prevention is at the heart of what we do. Although we cannot prevent the occasional and unfortunate misrepresentation of an individual borrower or an employer providing inaccurate or misleading financial information, our dedicated and experienced team knows how to flush that out and is trained to probe the questionable.

The human factor here is why we continue to pursue further development initiatives and enhancements within our own systems, integrations and operations. eVoE™ allows us to sidestep the inconsistencies

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Roisin Lakings CFO of Advanced Data that occur when relying on a hard copy 1005 and the more conventional methods of faxing and email. Utilizing eVoE™ allows employment or income verifications to happen digitally and securely with an audit trail that accounts for every individual that ‘touches’ that document.

Advanced Data’s participation in Fannie Mae’s Day 1 Certainty® or D1C initiative is also evidence of our resolute commitment to our operations and verification processes. We have been scrutinized, combed through,

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Advanced Data is dedicated to the verification process. We are the only DU Validation Service provider that is solely focused on the verifications segment. Our partnerships with Equifax’s TWN, Finicity’s Verification of Assets (VOA), PitchPoint’s Fraud Reports and ServiceLink’s Flood Zone Determination along with our direct connection to the SSA and IRS, makes our all-inclusive suite of products truly a Single Source Solution for Verifications.

COVID-19 certainly played a role in pushing the digital mortgage experience along, forcing lenders to adopt policies, procedures and partners that enable them to continue to meet consumer demand amid this year’s record breaking mortgage and refi volume. The pandemic has pushed much of 27

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turned over, tested and quality controlled to ensure accuracy and implementation of best practices. The assiduous due diligence we participated in revealed the true quality of the products and services we return to our clients. It ultimately proves our value to the lender and the ROI is huge, not only for them but for us. In terms of efficiency we are processing verifications of employment and income in record numbers, and doing so with precision, record turn times, and maintaining the highest quality verifications driven by regulatory compliance.

Our integrations with Ellie Mae’s Encompass, Calyx Point or Lending QB, to name a few, along with our very own proprietary software for direct ordering, make us a notable vendor of choice. Couple these technology-driven partnerships with digital products such as Verification of Assets (VOA) or Payroll Data Verification, Advanced Data is again on the front line, leading us to expanded partnerships with leading nationwide payroll companies. The continued need to develop integrations that solve the ongoing challenge of human error when verifying consumer employment and income can and will be resolved

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November 2020

to satisfy consumer privacy laws and hastouches presented many firms with new challenges that come with managing a remote workforce This push to remote working is proving that the mortgage industry is ready for the technology that has been knocking on its door for over a decade.

Borrowers want a digital experience, they are used to a digital experience and have come to trust the digital experience: think Amazon. Now more than ever consumers are busy juggling work, distance learning, health concerns, community initiatives, social and political issues all while finding a work-life balance that is sustainable. Advanced Data understands this, having already established the foundation of a remote corporate culture.

We have a long track record of leveraging a variety of communications platforms to stay connected, organized, to cultivatecommunications and optimize team dynamics at all levels of our organization. This experience has enabled us to develop and sustainably grow the best verifications fulfillment team in the industry.

Technology

BEYOND THE POINT-OF-SALE:

Benefits of an End-to-End Digital Mortgage in a Post-Pandemic World

By Parvesh Sahi, Ellie Mae, part of ICE Mortgage Technology

COVID-19 has forced the digital mortgage to become an industry-wide reality as lenders look to meet borrower expectations by offering a remote and automated experience. Through online applications and borrower portals, lenders have quickly pivoted to ensure the safety and security of homebuyers by providing a complete virtual experience. True digital mortgage solutions extend well beyond the point-of-sale and the borrower’s experience. These digital solutions can create operational efficiencies, revenue and profitability gains, improved talent acquisition and retention, and growth opportunities. Lenders must move beyond concentrating on just the borrower ‘UI’ and ensure they have an end-to-end digital operating model in place in order to achieve competitive advantage and long-term success.

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This process starts by streamlining operational efficiencies and harnessing data to drive decision making. Digitizing and automating workflows, such as service ordering, underwriting, and data gathering on borrower and collateral profiles, allows lenders to spend more time building personal relationships with borrowers and focusing on new business opportunities. At the same time, to the extent that lenders can enable realtime pricing and hedging data updates, they can customize loan level day-one insights to optimize profitability. By implementing these automated processes within the same digital mortgage ecosystem, lenders are able to

The MORTGAGE BANKER Magazine

reduce costs and time-to-close and provide competitive and highly profitable pricing, while building consumer trust and affinity.

What’s more, with a robust back-end digital mortgage strategy and framework, lenders are better equipped to capitalize on the increased interest from borrowers who are engaged by the lender’s front-end digital POS offerings.

Digitizing back-end processes also creates a streamlined working environment for employees and makes for an attractive workplace of choice. Free from rote, manual tasks, employees are happier and more focused on the strategic aspects

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Technology

of their roles; thus, they are more fulfilled and likely to stay at their company. As we have seen during COVID-19, lenders are fighting to keep their talent, but also understand there are times to increase staff and times to reduce due to seasonality and volume fluctuations. As the most experienced and highly talented mortgage employees receive offers with higher wages from other companies, they consider their job satisfaction and longevity in the role when deciding whether to stay or leave.

While digitization can provide numerous advantages for a lender, companies still need the best loan officers and underwriters in order to succeed as technology continues to evolve. When riddled with overcomplicated and analog loan approval processes, top talent quickly finds new roles with competitors. Top performers will experience increases in both happiness and productivity when they’re able to complete their work faster through a streamlined digital mortgage process.

Additionally, when a fully end-to-end digital mortgage ecosystem is realized and repeatable, loan quality increases. In turn, GSEs or private sector aggregators in the secondary market begin to evaluate lenders’ loans more favorably. When all steps of the mortgage process can be completed within the same integrated portal, lenders avoid the need to log into a third-party platform which may be riddled with inefficiencies or errors. Keeping work centralized alleviates third-party risks and speeds accurate and realtime communications between the originator and lenders. Secondary market entities segment their counter-party risk by approving lenders more quickly that have a history of quality loans, increasing a lenders’ overall revenue. Efficiency is not only imperative to process loans internally, but also to expand

The MORTGAGE BANKER Magazine

opportunities and get better execution and pricing from the secondary market.

For example, in May 2020, MarketWise Advisors, LLC (MWA) independently evaluated the loan delivery process from lenders delivering loans from Ellie Mae’s loan origination system, Encompass, to their correspondent investors. MWA surveyed loan delivery, shipping, secondary marketing, and investor professionals using Encompass and found significant endto-end savings, efficiency, and improved ROI when loan packages were delivered directly from the loan origination system to the investor. Lenders were surveyed about the loan quality, purchase conditions, time to funding, staffing requirements, and pricing when delivering loans to investors from Encompass. Lenders delivering loans to participating investors from within Encompass experienced improvements in loan quality, delivery, and purchase times resulting in financial benefits in direct operational time savings, improvements to data quality, and reduction in back and forth between lenders and investors. Ultimately, lenders experienced an average time savings of 39 minutes per loan file and over $20 per loan in operational savings.

Over the last 10-15 years, lenders have been gradually adopting digital mortgage offerings, but COVID-19 has proven the need for an integrated digital mortgage platform now more than ever. Implementing a holistic digital mortgage yields a variety of benefits including sales growth, operational efficiency, employee retention, and a differentiated, sustainable growth model. Taken together, a digital mortgage experience can drive a quantifiable bottomline impact. MBM

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Loan Origination

Eliminating the Unknowns from VA Loans An interview with Jimmy Vercellino, Goldwater Bank

By Brian Honea

The market share for residential mortgage loans guaranteed by the U.S. Department of Veterans Affairs has surged in the last decade or so from 2 percent to over 10 percent. So far in 2020, about 1.2 million VA-backed mortgage loans have been made, totaling $375 billion in volume with the average loan at $301,000, according to the VA’s latest statistics.

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These numbers indicate that more and more veterans are obtaining mortgage loans guaranteed by the government. More than 1,400 lenders have made at least one VA-backed loan this year, the VA reported, but 10 of those lenders account for nearly half of those 1.2 million loans, which indicates that, while progress has been made, there is more that can be done in the area of VA lending. And making lenders more aware is a step in that direction. Jimmy Vercellino, a top producing loan originator for boutique lender Goldwater Bank N.A. in Phoenix recently discussed with The MORTGAGE BANKER Magazine the issue of educating the industry on VA loans. Vercellino, who served in the U.S. Marine Corps and served honorably in Operation Iraqi Freedom, has made his mission to provide and assist all veterans and active duty military with all of their VA home financing needs.

away and in many circumstances can even have more than one at a time. It’s the only loan in the nation that allows our Veterans to finance a home up to any loan amount they'd like with no down payment required. On top of all of that veterans can use their benefit to buy a condo, a fourplex (four-unit property) and they can even use their VA loan benefit to build a house (construction-topermanent) in conjunction with their VA loan.

While I have seen LOs place a higher priority on helping veterans secure home financing, there are still many in the marketplace who are not aware of these important details. In addition, a majority of MLOs attempt to work on a VA loan, without understanding how it works. It would be the equivalent of me going to a podiatrist for shoulder pain. Yes, they are both physicians, but have two entirely different skill sets. For another example, if you have a Marine Corps infantryman working on electrical equipment and another specializing in avionics, you wouldn't want the Marine infantryman touching avionics equipment in the same way you wouldn't want the avionics Marine using a Mark 19 or 240 automatic weapon.

MBM: What is happening right now in the marketplace where VA loans are concerned?

Jimmy Vercellino: Earlier this year, the VA loan limit cap was removed, which now allows our veterans and active duty servicemembers to finance a home up to any purchase price they would like, so long as they qualify by way of credit score and income.

In my observation there are loan originators who still do not understand and are not aware of this latest update. While I have seen VA loans become en vogue over the last three to five years, it has been my experience that there still remains a significant amount of unknowns permeating throughout the marketplace. Some unknowns from the originator’s perspective I have seen are, “Hey, what do I ask the Veteran for?” “What documents do we need?”

And at the same time, there continues to be a tremendous desire for valuable information coming from the veteran and active duty servicemember’s perspective about what really exists with the VA guaranteed loan. We as originators must be able to explain to Veterans and Active Duty exactly how it works. Servicemembers need to know that their VA loan benefit never expires, never goes

The MORTGAGE BANKER Magazine

MBM: Why are there still a lot of unknowns where VA loans are concerned among originators and in the industry?

Jimmy Vercellino: Since the Department of Veterans Affairs does not advertise the VA loan or educate originators, who is responsible? The answer may surprise you. Educating LO’s regarding VA Loan benefits is entirely up to the company providing the funding and the originator. Together they are responsible for learning the information via resources such as the VA Lenders Handbook, individual lender guidelines and seeking to understand how the VA loan works. It is important to remember, the VA does not advertise it.

It’s up to mortgage originators and mortgage companies to take the information regarding VA loan benefits and disperse it to the marketplace.

In my opinion, we are not doing a good job of that. How can we expect our veterans and our real estate professionals to know the important

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Loan Origination details? The answer is, without a VA loan specialist such as me, they don't and they won’t.

I teach real estate agents and veterans all across the nation every single day on my YouTube channel and on Zoom meetings and there are constantly veterans reaching out saying, “I had no idea that I could do X, Y, or Z with the VA loan.” I think it's just the failure of getting out that information from the top down, top being VA mortgage originators and mortgage companies, and dispersing it out to the marketplace, which are veterans, active duty military, and real estate agents.

how agents can serve veterans and active duty servicemember buyers. In addition, lenders are also learning via our valuable YouTube video content.

There's definitely no question that this valuable information our industry is providing is helping more veterans take advantage of their benefits, to which they are... I don't like to use this word very often, entitled.

As lenders we are doing what we can, but ultimately, it’s going to take veterans working with local mortgage originators who have educated themselves on VA loans to continue to spread this good news. I think this fight is going to be constant.

I believe it is going to continue being a need with more and more veterans who are leaving the military, starting lives, and starting their families.

These men and women will crave this information and will ultimately need educated originators to ensure their VA home loan is done the right way for them. MBM

MBM: What can be done to educate the industry more about VA loans?

Jimmy Vercellino: I am doing what I can to provide important information to the marketplace. I founded a school called School of Veterans Home Financing where we've been educating thousands of real estate agents across the nation over the last 10 years on how the VA home loan works and

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THANK YOU VETERANS! and HAPPY VETERANS DAY from THE

BANKER

MAGAZINE

Loan Origination

How VA Lending Has Changed An interview with Michael “Mo” Oursler, chief operating officer with VA fintech lender, NewDay USA

By Brian Honea

One of the goals of the Blue Water Navy Vietnam Veterans Act of 2019, which was passed last year

by Congress and went into effect on January 1, 2020, was to make it easier for servicemembers to obtain mortgage loans. Much has happened in the nearly one year since this legislation took effect, including more changes brought on by a global pandemic that first slowed things down for the mortgage industry but then saw things take off as homebuyers and homeowners rushed to take advantage of low interest rates. Michael “Mo” Oursler, chief operating officer with VA fintech lender, NewDay USA, recently discussed with The MORTGAGE BANKER Magazine how this legislation has changed VA lending.

The MORTGAGE BANKER Magazine

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November 2020

to the property. In certain cases, they might allow them to do a drive-by appraisal, or in certain cases they may allow them to do a desk appraisal and they wouldn’t have to go out to the property; they can just do it based on data available.

There are certain other changes like when you’re already in a VA loan, you no longer have to get a water test because the veteran is already living there. The VA loosened up a lot of their property requirements while understanding the COVID implications of the loan process.

MBM: Since it’s been months since these changes took place, what effect has that had on VA lending?

Michael Oursler: VA lending is extremely robust right now. In fact, it’s so robust that NewDay USA is projected to surpass its 2020 estimates while more than doubling its revenue to over $300 million this year, up from $152 million in 2019. We are on pace to serve over 20,000 veteran families in 2020, and we expect to serve more than 40,000 in 2021.There are record levels of VA loans being done in the market right now and I believe the rate environment is the primary driver of that, although the changes also played a role.

MBM: What exactly was the big change that went into effect on January 1 as part of the Blue Water Navy legislation?

MBM: Have these changes given veterans better access to loans?

Michael Oursler: The short answer is yes. We’ve seen it in our business. There’s no denying that the changes give veterans more access and makes it a better experience for them. A VA home loan is a great product for the military. There are a lot of good reasons that military personnel would want a VA loan. Anything that’s done at the program level that makes the process streamlined or more accessible is a positive for everybody.

The VA no longer caps their guarantee of 25 percent at the county loan level. They will guarantee 25 percent of the loan even if it’s over the county loan limit as long as the veteran hasn’t used his or her entitlement before.. It allows military buyers to look at properties over the jumbo limit in their corresponding counties and regions, giving them access to 100 percent loan-to-value, and no down payment loan products even if it’s higher than the county loan limit. It definitely gives them more access to make offers on those properties. MBM

Michael Oursler: The VA made a change which made the limits not applicable on a large portion of loans, which helps military affordability, because now there are more homes over the county loan limit that they’re able to purchase. The VA will guarantee 25 percent of the loan amount regardless of the county loan limit, which makes the finances more accessible. That was a pretty big change.

MBM: What changes were brought on by COVID? Michael Oursler: There were some process changes in May. The VA did a really good job of being flexible with mortgage loans while the rest of the country was in lockdown and they still have some of these flexible policies in place. Generally speaking, regarding appraisals and all those property-related inspections that the VA requires, they’ve given lenders and appraisers a lot more autonomy to make judgment calls when they are unable to get The MORTGAGE BANKER Magazine

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November 2020

Loan Origination

WHAT CAN YOU DO TO RAMP UP YOUR MORTGAGE MARKETING?

By Luke Shankula, Paragon Digital Marketing

L

ike any other market, the mortgage market is subject to changes in supply and demand. As soon as we get a hint of where supply and demand are going, we better understand where the market itself may be headed.

Many people were predicting 2020 would be a major year for the mortgage market. The problem? COVID-19. As early as March, optimism over buying a home shifted from 75 percent to 43 percent, almost as if demand was about to collapse overnight.

The MORTGAGE BANKER Magazine

This presents an overwhelming opportunity for mortgage lenders. But before we get to what you can do to ramp up your marketing in Q4, first it’s time to establish two basic facts: • Mortgage demand is doing just fine. In fact, the Federal Reserve recently announced it could keep rates this low until 2023. This is ample time to market mortgages to new home buyers.

• Supply and demand show that home buying is healthy. I dug into it with some research below.

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WHY SUPPLY MAY BOOST THE MORTGAGE MARKET It’s easy to point to the COVID-19 pandemic and new social distancing rules and declare: “housing is about to crash.” But if the future were that easy to predict, we’d all be rich. Turns out, it isn’t. It takes honest research and a sense of multiple variables to understand where the mortgage industry is heading. And, as I reviewed the numbers, some things stood out about supply:

marketing efforts don’t resonate with people, you do not have a lagging market to blame.

MARKETING IN A UNIQUE ENVIRONMENT—AND CAPITALIZING IN QUARTER 4 OF 2020 So, with the above in mind, what are my conclusions about how you can better position your mortgage marketing?

• Capitalize on enthusiasm—because it’s there.

Let people know that it won’t be every year the Federal Reserve says that rates will be this low.

Mortgage borrowers can capitalize on a unique time in monetary history by acting sooner rather than later.

• Sellers took their homes off the market, reducing supply. One of the first impacts of the COVID-19 pandemic on housing supply? People simply started removing their homes from the market. Some reports have this rate moving from 3 percent to 16 percent. This is why you need to consider multiple variables: demand alone isn’t always enough to move the market downward.

• Set yourself up for a strong 2021. Use lead nurturing tactics to keep people around, such as creating an email newsletter for your website.

This will enable you to tap potential leads in 2021; and, as we know, the statistics suggest that those leads may still want a home in 2021.

• Experts call the changes in supply/demand a “temporary softening.” Keep in mind that these numbers are back when things seemed really dire, just as the pandemic kicked off. The chief economist of NAR, the National Association of Realtors, called the COVID-19 impact on the real estate market a “temporary softening.”

• Start a lead generation program. You need to have a lead generation strategy in place. If you don’t, you may lose out to a company that does.

As the old saying goes, “If you’re failing to plan, you’re planning to fail.” Lead generation needs to be a top priority as you market in this unique environment.

Mortgage marketing takeaway: You can honestly tell people that this is still a hot time for a mortgage.

The research doesn’t just back that up, but it points to a potential rebound in the fourth quarter of 2020.

• Leverage today’s software tools. Whether you’re using a site like LeadPages to create landing pages for your mortgage offerings, or using MailChimp to boost your email marketing, now is the time to create the infrastructure.

Because, as I’ve demonstrated, the mortgage market isn’t going anywhere.

PROJECTING THE MOVES IN THE REAL ESTATE MARKET IN LATE 2020 AND 2021 More recent statistics point to continued pressure on supply keeping prices up. For example, new listings have been down 12 percent. Total inventory? Down 39 percent. That comes from Realtor.com data released on September 5,2020.

What should we make of this data? It isn’t complete until we also look at new home sales, which have also been higher than expected. For instance, the Home Purchase Sentiment Index increased during August, suggesting that there is some momentum for the mortgage market going into the last quarter of 2020.

• Use social distancing and stick to the rules. If you’re showing a lot of homes as a real estate agent, for example, utilize tools like Calendly to set up Zoom calls and virtual meetings. There’s no reason you can’t still get work done.

The mortgage market is healthy and it looks like it may stay that way for a while. As I looked through the research, I found that the fourth quarter of 2020 may be the ideal time to position yourself in for success in 2021. And considering where the winds are pointing, there may not be another opportunity to prepare yourself quite like this one. MBM

Mortgage marketing takeaway: There is plenty of ample sentiment out there. If your mortgage

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November 2020

Loan Origination

Why Housing Market Potential Remains High

By Mark Fleming, First American

T

he housing market’s impressive “V-shaped” recovery has thus far shown significant resilience to the economic impacts of the coronavirus pandemic. Demographicallydriven millennial demand has continued unabated, low rates have fueled house-buying power, and historically low inventory has increased competition, leading to rising prices.

Weekly mortgage applications started the first quarter of the year approximately 10 percent above year-ago levels. After reaching a pandemic-induced low point in April, mortgage applications began to The MORTGAGE BANKER Magazine

accelerate and, starting in late May, have surpassed their levels from one year ago for 21 straight weeks.

In September, housing market potential continued to impress, even outpacing last month’s record.

Housing market potential increased to its highest level in over 13 years, largely driven by strong house price appreciation in September.

HOUSING MUSICAL CHAIRS BOOSTS MARKET POTENTIAL In today’s housing market, fast rising demand against the limited supply of homes for sale has 40

November 2020

resulted in faster house price appreciation. There were 1.49 million homes for sale at the end of August, down 18.6 percent annually to a 3-month supply. Homes that do come to market are often met with multiple bids, further escalating prices, but are still selling quickly. The rapid escalation of house prices has a mixed impact on home buyers, fueling strong equity gains for existing homeowners, but dampening affordability for potential first-time homebuyers.

Homeowners in areas where house prices are rising feel wealthier. American homeowners today have near-record levels of equity, and, as their equity grows, they are more likely to consider using that equity to purchase a larger or more attractive home, the wealth effect of rising equity. In August’s existing-home sales report, the increase in home sales was strongest at the upper end of the market, as sales of homes priced at more than $1 million rose 44 percent nationally, followed closely by homes in the $750,000 to $1 million range, which increased 34.5 percent. Existing homeowners are playing “housing musical chairs” by selling to each other. In September, the growing wealth effect of rising equity caused by house price appreciation increased housing market potential by 26,570 potential home sales relative to one month ago, and 129,430 compared with one year ago. Accelerating The MORTGAGE BANKER Magazine

house price appreciation had its greatest yearover-year contribution to the market potential for existing-home sales since 2014.

WHAT’S AHEAD FOR FIRST-TIME AND REPEAT BUYERS? Inventory in today’s housing market is so tight and demand so strong that in last month’s existing home sales report, 70 percent of all homes listed for sale were sold within the month, with days on market falling to 22 in August, down from 31 days in August 2019. The ongoing supply shortage continues to put upward pressure on house price appreciation as buyers compete to buy what little inventory is for sale. You can’t buy what’s not for sale, but you can compete for what is.

The lack of inventory and increase in house price appreciation is problematic for potential first-time home buyers, who tend to be younger and do not have the equity from the sale of an existing home to bring to the closing table. On the contrary, existing homeowners can use the equity from the sale of their current home to purchase a bigger or better home.

Rapid house price appreciation and its impacts on existing and first-time home buyers will persist until the supply and demand imbalance begins to improve. In the game of housing musical chairs, it’s clear the housing market needs more chairs. MBM 41

November 2020

Compliance

The Importance of a Robust CMS Structure

BY FELECIA BOWERS, HOMEOWNERS FINANCIAL GROUP

FOCUS. Miriam-Webster defines focus as “to concentrate attention or effort, i.e. focus on the most pressing needs.� The problem with focusing on that definition is that, as a compliance professional, our focus shifts daily or hourly depending on the latest announcement in our email bucket.

Internal emails shift us to focus on an internal issue that may impact a loan transaction from moving forward, a compliance hiccup that exposes our company to enforcement fines, a loan sale that cannot be consummated, or a repurchase request due to a compliance problem. Where to focus is going to be a personal decision. What is a priority for one may not be for someone else. So, let me throw out a few items that that may require you to shift your focus.

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Advertising enforcement actions were announced by the CFPB against eight mortgage lenders and brokers in the past few months over direct mail campaigns marketing VA-guaranteed loan products. What part of the “Truth in Lending Act” did these organizations not understand?

I must ask the same question about the Unfair Deceptive Abusive Acts and Practices, highlighting the word “deceptive.” APRs were not accurate, the campaigns advertised loans as fixed rate when in fact they were adjustable rate, and implied they were affiliated with the VA, etc.

These recent enforcement actions by the CFPB stand to highlight the importance of a robust CMS program covering all things advertising. Should this be your focus of finetuning your CMS program? Remember, you should have a CMS program that is consistent with the size, complexity, and risk profile of your company. YET, every company out there bases their advertising platform on how different they are than the rest of the pack. Great…no pressure here to get it right!

Or should your focus be on a deep dive into your advertising program? Have you searched the web, Facebook, Twitter, and YouTube for your loan officer’s names lately? We subscribe to a service that does this for us, but some companies cannot afford a vendor. “The budget” or “no time” are not valid reasons with examination teams when they ask how you monitor your MLO populations advertising. You desperately need to make that time to review federal and state advertising requirements vs. social media.

Regarding the states, they are checking their respective Secretary of State websites for other employment with which your loan officer staff may be involved. They are looking for violations of other activities the MLO did not list on the NMLS. There is a question on their profile page asking if they are engaged in other businesses.

If they answer yes, they must disclose certain information. Is your company employing the NMLS to review this question at the time of hire or as part of your prescreening efforts? And, if you learn of a side gig the MLO is engaged, are you making sure their NMLS profile is current?

And speaking of time, November is the The MORTGAGE BANKER Magazine

renewal period for every mortgage banker, broker, and loan originator in the country via the NMLS. Do not wait until the last minute to push out your company renewals as competition is fierce. Compounding the last-minute push is the fact that state agencies are strapped due to their own budgets and some still have remote deployment of their workforce.

Did I say renewals? Do not forget your HUD renewal. If you had a company event such as an ownership change or have a pending lawsuit, you may need to get HUD’s approval to re-certify for their renewal. If you have not disclosed said event or suit, you should take a few moments to read the criteria for disclosing and take care of the task immediately. It can take them three to six weeks to respond and clear the path to renewal.

On the subject of paths, we have a clear path in front of us rolling out the new URLA. Take a moment to review your game plan so you are ready for the March 1, 2021 implementation date.

By now your company should have decided if you are going to provide all borrowers with all pages, the primary borrower with all pages and the co-borrower with just their page, no one will receive the lender page, or some other hybrid delivery. Be sure to monitor the transition period for loans in the pipeline, especially builder loans which hang around for several month between origination and closing.

How apropos to end the previous paragraph on closing because if you missed the webinar

by MISMO introducing the Uniform Closing Instruction Templates, you missed a lot. Uniform closing instructions have been bantered around for many, many years. I remember working on this project back in the 90s, so I am crossing my fingers this one completes the development and introduction cycle. A uniform set of closing instructions has been something the closing industry has requested for 20+ years. MISMO has changed the focus from common language, the sticking point, to creating a standardized template to a focus based on format. I’m fairly confident we do not have “common language” in this industry. The focus on format will allow settlement agents to streamline where they need to look and at what to look.

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Compliance Sliding into something to look at, the FTC has requested comments on five different proposals relative to the Fair Credit Reporting Act which they hope to bring in alignment with the Dodd-Frank Act. Notices of Public Rulemaking are requested on (a) address discrepancy rules; (b) affiliate marketing; (c) furnishers of information; (d) prescreen opt-out notices; and, (e) risk-based pricing.

Risk-based pricing comments and compliance is the perfect transition to remind everyone to review HUD’s finalization of disparate impact regulations under the Fair Housing Act. The guidance seems to shift the burden of proof relative to a discrimination claim to the Plaintiff.

Be sure to get your HMDA data analyzed for fair lending issues, and review your overall company for fair lending and discrimination.

Transitioning into discrimination, per the CFPB’s announcement on August 19, 2020, the Consumer Financial Protection Bureau (Bureau) announced that it will provide an additional 60 days for public comment on its Request for Information (RFI) on how best to create a regulatory environment that expands access to credit and ensures that all consumers and communities are protected from discrimination in all aspects of a credit transaction. The extension for submission of comments provides interested parties with more time to conduct outreach to relevant constituencies and to address the many issues raised in the RFI. The original deadline for submissions was October 2, 2020. The comment period will now close on December 1, 2020.

Remember that the Equal Credit Opportunity Act (ECOA) and Regulation B make it unlawful for any creditor to discriminate against any applicant, with respect to any aspect of a credit transaction on the basis of race, color, religion, national origin, sex or marital status, or age; because all or part of the applicant’s income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The information provided will help the Bureau continue to explore ways to address regulatory compliance challenges while fulfilling the Bureau's core mission to prevent unlawful discrimination and foster innovation.

The MORTGAGE BANKER Magazine

To read the RFI click here: https://files. consumerfinance.gov/f/documents/cfpb_rfi_ equal-credit-opportunity-act-regulation-b_ comment-period-extension.pdf.

On the topic of the CFPB, they have certainly been busy. They have published a new reference tool for 2021 HMDA Data to be collected in 2021 and reported in 2022. They issued new MSA Guidance replacing the former RESPA Section 8 FAQs. On October 5th, they issued a policy statement on relative applications for early termination of Consent Orders. Also, in October, they released a TRID Assessment that is worthy of your reading time budget.

And relevant to budgets, now is the time to get in front of your executive team relative to your compliance budget for 2021. The pandemic did not suppress loan production, and, in fact, pipelines were swollen to the brim re-introducing the concept of a stay-cation. Families purchased RVs and put in pools and backyard oases for friends and family to visit and to keep the kids occupied while we worked from home, lounging by the pool. The budget. Now is the time to ask for assistance (internal or external) in the compliance department. Quote the tidbits cited above plus a plethora of postponed internal risk assessments; dedicated attention to MLO and company advertising activities; MSA Reviews and documentation; new and revised rules; new forms; scrutiny of HMDA data for fair lending; increased exams (I’m working on seven right now); and, compliance train is never ending. I learned years ago that if I continue to hoard my responsibilities or work 70+ hours per week, no one at the top will see that there is a staffing or vendor assistance needed in compliance.

The work is getting done but at what cost?

Ramping up production staff and operations staff is great, but if the compliance support to mitigate enforcement fines, compliance failures on loans destined for sale, and the entire CMS infrastructure is not in place, the rest will fall apart. MBM 44

November 2020

From the Desk of the ‘Om-Bobs-man’

"Om-Bobs-Man" is the nickname Bob Niemi earned while serving as the NMLS Ombudsman in 2014 and 2015. Bob is a former Ohio state regulator and now an expert consultant on NMLS and state regulatory matters. Bob can be reached at BNiemi@Bradley.com.

Deadlines, Deadlines, Deadlines…

N

ovember is the month we give thanks and remember our Veterans; it is also the month of renewals in the NMLS. For those who are actively deployed, many states have processes and regulations in place to provide benefits to active duty and veterans of the United States Armed Forces and National Guard of any state.

More details on those programs can be found by searching on the NMLS Resource Center or checking with your home state agency.

For the rest of us, November is NMLS Renewal Period and lasts from one to ninety days and sometimes more. While the most common timeframe for renewals is from November 1st through December 31st, there are a few states with shorter periods. There are also a few other states with stricter guidelines for renewals.

Condensed Renewals If you do business in West Virginia, hopefully your renewal is already in process. While not a hard deadline, renewal requests submitted after November 2nd may not be approved before the end of the year. The challenge to a late renewal is that if the

renewal has not been approved, all activity in the New Year must cease until the renewal has been approved.

Similar issues will impact companies in Idaho, Iowa, Kansas, Wyoming, and some Vermont mortgage licenses.

This is not an exclusive list. Their December 1st submission date is to guarantee a review prior to year-end to prevent a cessation in mortgage activities until the license renewal is approved.

But note that the Kansas renewal deadline is by statute.

So, please double check that renewal.

December 15th brings more states into the mix with Minnesota and Washington.

Some states like Wyoming and Minnesota do not allow a company to operate in the New Year even if the renewal request was submitted within the renewal period but not approved prior to the end of the year. No one wants to send the email notification that your originators must cease all business activities in a state until the renewal has been approved. Yes, that is another reason to double check that your renewals have all been requested.

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Reinstatement Some states do offer reinstatement with added fees, but not all states. Iowa has a December 1st submission, and late submissions must be approved by December 31st for lenders to operate in the New Year. Further, there is no reinstatement and companies who fail to submit a renewal by December 31st are moved to terminated-expired status. These companies would begin with a new license submission. But no one is picking on Iowa since similar circumstances exist in Idaho, Illinois, New Hampshire, South Dakota, and West Virginia.

Now, if you believe that this is enough already, consider your continuing education deadlines.

Georgia’s state specific education must be completed

by Halloween. Washington, D.C. and West Virginia provide one more day to November 1st.

There are five more states that have December 1st for their education completion deadline.

Give thanks that all this is available on the NMLS Annual Renewal Page at www. nationsidelicensing.org. MBM

Compliance

REGULATORY CORNER FEDERAL COMPLIANCE FLOOD PROGRAM EXTENDED The president signed H.R. 8337 on October 1, 2020. Section 146 of the "Continuing Appropriations Act, 2021 and Other Extensions Act" postponed the expiration of the National Flood Insurance Program for one year, to September 30, 2021. Language was included to bridge the gap between the September 30, 2020, expiration date and the signing date.

CFPB ISSUES RESPA SECTION 8 FAQS The CFPB published guidance on October 8, 2020 in the form of FAQs on RESPA Section 8 topics. The FAQs, which the CFPB issued as a Compliance Aid, provide an overview of the provisions of RESPA Section 8 and respective Regulation X sections, and address the application of certain provisions to common scenarios described in CFPB inquiries involving gifts and promotional activities, and marketing services agreements (MSAs).

The CFPB also said it has determined that Compliance Bulletin 2015-05, "RESPA Compliance and Marketing Services Agreements," does not provide the regulatory clarity needed on how to comply with RESPA and Regulation X and therefore is rescinding it. The CFPB’s rescission of the Bulletin does not mean that MSAs are per se or presumptively legal. Whether a particular MSA violates RESPA Section 8 will depend on specific facts and circumstances, including the details of how the MSA is structured and implemented. MSAs remain subject to scrutiny.

FHA CATALYST NOW AVAILABLE FOR MULTIFAMILY LENDERS On October 14, 2020, the FHA announced the availability of the first module of its FHA Catalyst technology platform for Multifamily lenders doing business with FHA. The module will allow eligible lenders to electronically submit applications for FHA insurance on multifamily properties. The new capability supports lenders in providing FHA-insured mortgage financing while working remotely because of the COVID-19 pandemic.

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November 2020

FRB PUBLISHED CRA ANPR The Federal Reserve Board published [85 FR 66410] in the October 19, 2020 Federal Register its September 21 Advance Notice of Proposed Rulemaking to solicit public input regarding modernizing the Board's Community Reinvestment Act regulatory and supervisory framework. Comments are due by February 16, 2021.

CFPB POSTS HMDA DATA REFERENCE CHART FOR 2021 On October 15, 2020, the CFPB posted the "Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2021," which can be used as a reference tool for data points required to be collected, recorded, and reported under Regulation C, as amended by the HMDA Rules. Relevant regulation and commentary sections are provided for ease of reference. The chart also incorporates the information found in Section 4.2.2 of the 2021 Filing Instructions Guide and provides when to report not applicable or exempt, including the codes used for reporting not applicable or exempt from section 4 of the 2021 Filing Instructions Guide for ease of reference.

FHFA PROPOSED RULE FOR NEW ENTERPRISE PRODUCTS AND ACTIVITIES The FHFA is seeking comments on a notice of proposed rulemaking that would require Fannie Mae and Freddie Mac to provide advance notice to FHFA of new activities and obtain prior approval before launching new products. The proposed rule would also establish revised criteria for determining whether a new activity requires notice to FHFA and for determining if that activity is a new product that merits public notice and comment. The proposed rule would replace the interim final rule that has been in effect since 2009.

The proposed rule’s requirements would also outline the process for FHFA review of a new activity and the timelines for approving a new product, including issuing a public notice and requesting public comment about a potential new product. Comments on the proposal will be accepted for 60 days following Federal Register publication.

FANNIE MAE AND FREDDIE MAC EXTENSION OF COVID-19 LOAN FLEXIBILITIES The FHFA announced on October 19, 2020 that Fannie Mae and Freddie Mac will extend several of their loan origination flexibilities until the end of November, 2020. The changes are to ensure continued support for borrowers during the COVID-19 national emergency. The flexibilities were set to expire on October 31, 2020.

The extended flexibilities include: • Alternative appraisals on purchase and rate term refinance loans; • Alternative methods for documenting income and verifying employment before loan closing; and • Expanding the use of power of attorney to assist with loan closings.

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November 2020

Compliance

FHA FORBEARANCE EXTENSION On October 20, 2020, the FHA announced that it is extending the date for single family homeowners with FHA-insured mortgages to request an initial forbearance from their mortgage servicer to forbear their mortgage payments for up to six months.

Homeowners experiencing a financial hardship as a result of the COVID-19 pandemic may now request an initial forbearance through December 31, 2020 (the deadline was previously October 30). The FHA requires mortgage servicers to: • Offer homeowners with FHA-insured mortgages mortgage payment forbearance when the homeowner requests it, with the option to extend the forbearance for up to a year in total. FHA does not require a lump sum payment at the end of the forbearance period.

• Assess homeowners who receive COVID-19 forbearance for FHA's special COVID-19 National Emergency Standalone Partial Claim before the end of the forbearance period. This program puts all suspended mortgage payment amounts owed into a junior lien, which is only repaid when the homeowner sells the home, refinances the mortgage, or the mortgage is otherwise extinguished.

• Assess homeowners who are not eligible for the COVID-19 National Emergency Standalone Partial Claim for one of FHA’s COVID-19 expanded home retention solutions announced on July 8, 2020.

CFPB FINAL RULE ON GSE PATCH EXTENSION The CFPB issued a final rule on October 20, 2020 to extend the GSE Patch until the (yet to be established) mandatory compliance date of a final rule amending the General QM loan definition in Regulation Z. The GSE Patch was scheduled to expire on January 10, 2021. The CFPB is not amending the provision in Regulation Z stating that the GSE Patch will expire if the GSEs exit conservatorship.

The GSE Patch provides QM status to certain mortgage loans eligible for purchase or guarantee by either of the GSEs. GSE Patch loans are eligible for QM status even if the borrower's debt-to-income ratio exceeds 43 percent. The rule extending the GSE Patch will be effective 60 days after it is published in the Federal Register. MBM

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November 2020

C O N N E C T. L E A R N . L E A D .

MBA’s REGULATORY COMPLIANCE CONFERENCE 2020

NOV. 9–10 ONLINE ONLY

In this ever-changing climate, good business is compliant business!

Get the latest updates and comprehensive guidance you need to keep your business on the right side of compliance only at MBA’s Regulatory Compliance Conference 2020.

Register today at mba.org/RegComp20

21970

MBA.ORG/REGCOMP20

Legal

The Mortgage Counselors Mitchel H. Kider is the chairman and managing partner and Michael Kieval is a partner with Weiner Brodsky Kider PC, a national law firm specializing in the representation of financial institutions, residential homebuilders, and real estate settlement service providers.

The CFPB’s Revised RESPA/MSA Guidance

B

ack in 2015, the CFPB made waves when it issued Compliance Bulletin 201505, which raised questions about whether the CFPB believed that marketing service agreements (MSAs) were permissible at all under Section 8 of RESPA. Five years later, on October 7, 2020, the CFPB rescinded that guidance, announcing a new set of FAQs on RESPA Section 8. We’d like to give you a few thoughts about what this all means for MSAs and for RESPA enforcement, generally, going forward.

The new FAQs are fairly straightforward, mostly tracking the statutory text of Section 8 as well as the relevant provisions of Regulation X. While at first glance the FAQs do not provide a lot of guidance beyond what we already knew, they are good news for our industry for two reasons.

First, the rescission of Compliance Bulletin 2015-05 is important because it is clear that the CFPB will apply the usual RESPA analysis to MSAs. Second, the FAQs should put to rest the CFPB’s earlier attempt to write Section 8(c)(2) out of RESPA. Under former Director Cordray, the CFPB took the erroneous position that reasonable payments for goods, facilities, or services were not covered by the Section 8(c)(2) safe harbor if the intent was to obtain referrals as part of the same transaction. Leaving aside the fact that their position, if taken to its logical conclusion, would

have banned mortgage brokering, that argument ran counter to decades of interpretations and guidance from HUD. The CFPB lost that fight in the U.S. Court of Appeals for the D.C. Circuit in the PHH case, with thenJudge Kavanaugh explaining clearly that a payment for goods, facilities, or services in an amount that bears a reasonable relationship to the general market value for such goods, facilities, or services, does not violate RESPA Section 8 even if there is an explicit agreement tying the provision of those services (for example) to a referral that also takes place. Judge Kavanaugh came to that obvious conclusion based on a careful reading of the statute. But it also makes sense from a practical perspective because compensable services are being provided and the payment is reasonable for the value of those services; any referral that may also be happening is not what is being paid for.

The CFPB’s new FAQs accept the holding of PHH and abandon the CFPB’s previous attempts to rewrite Section 8(c)(2) out of RESPA. The CFPB also reiterates the test for whether a service, good, or facility are compensable, namely that they must be “actual, necessary, and distinct,” and that any services cannot themselves constitute a referral, which is the same test that has been in place since HUD’s Home Warranty

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Interpretive Rule that was published in 2010.

All of this does not mean that all MSAs are necessarily compliant, however. In fact, the CFPB stated clearly that it will continue to scrutinize MSAs for compliance with RESPA Section 8. And you also face risk from other regulators, as well as from private class action attorneys.

In deciding whether to enter into an MSA with another settlement service provider, you should ask yourself the following questions: 1) Why do I value the services I am paying for? 2) Why am I paying this particular counterparty to provide the services instead of someone else? 3) Would the counterparty be performing these services even if I did not pay for them? 4) Are the services compensable under applicable regulatory guidance, or are they really describing referral activity? and 5) Do I have a reliable valuation of the services (generally from an unrelated third party) to show that I am paying reasonable market value?

If, working with your counsel, you believe you have satisfactory answers to all of these questions, you still need to carefully document that you are receiving all of the services for which you are paying. If some of the services are not provided, withhold payment.

Such an approach will go a long way towards helping your MSA withstand regulatory scrutiny and potential litigation. MBM

Legal

Mortgage Banking Lawyers These attorneys are universally recognized by their peers as setting the highest standard for the legal profession, excelling in all fields – knowledge, analytical ability, judgment, communication, and ethics.

Thomas F. Vetters II Managing Partner

Mitchel H. Kider Managing Partner

Thomas E. Black, Jr. Managing Partner

tvetters@ravdocs.com 512-617-6374

kider@thewbkfirm.com 202-557-3511

tblack@bmandg.com 972-353-4174

Thomas Vetters is the managing partner of Robertson Anschutz Vetters, LLC (“RAV”) where he has spent his entire legal career developing a comprehensive expertise in the mortgage lending and compliance industry and helped develop the firm’s 50-state document software Docs on Demand®. Thomas is Board Certified in Residential Real Estate Law by the Texas Board of Legal Specialization.

In his 35 years as a practicing attorney, Mitch has represented banks, mortgage companies, residential homebuilders, real estate settlement service providers, credit card issuers, and other financial service companies in a broad range of matters. Mitch represents clients in investigations and enforcement actions before the Consumer Financial Protection Bureau, Department of Housing and Urban Development, Department of Veterans Affairs, Department of Justice, Federal Trade Commission, Ginnie Mae, Fannie Mae, Freddie Mac, and various state and local regulatory authorities and Attorneys General offices. In addition, Mitch acts as outside general counsel to smaller companies and special regulatory and litigation counsel to Fortune 500 companies.

Thomas E. Black, Jr. is managing partner of Black, Mann & Graham, LLP. Founded in 1997, the firm has offices in Dallas, Flower Mound, and Houston, Texas. Tom practices in the area of residential real estate law representing many of the nation’s largest banks and mortgage companies. He has been admitted to the practice of law in New York, Texas, Iowa and Washington. In 1976, Tom received a B.A. degree from the University of Notre Dame. He received his J.D. degree from the University at Buffalo in 1979 and an M.B.A. degree from The University of Notre Dame in 2008. After holding senior positions with a number of national mortgage companies, he returned to the practice of law in Texas in 1995. A frequent mortgage industry lecturer, he taught more than 25 years in the Mortgage Bankers Association’s School of Mortgage Banking. He is active in community service and held a variety of board positions, and serves as a Trustee of the University of Buffalo Foundation and of Saint Mary’s College, Notre Dame, Indiana.

Thomas currently serves on the Board of Directors for the Texas Mortgage Bankers Association and previously chaired their Regulatory Compliance Committee, Education Committee and served on their Executive Committee.

Thomas has prepared and presented papers on Texas Home Equity, Privacy, Safeguards, Loan Originator Compensation, ATR/QM and the TILA/ RESPA Integrated Disclosures. He is admitted to practice in the State of Texas and the U.S. Western District of Texas. RAV’s offices include Houston, Austin, Plano, and The Woodlands.

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Mortgage Banking Lawyers These attorneys are universally recognized by their peers as setting the highest standard for the legal profession, excelling in all fields – knowledge, analytical ability, judgment, communication, and ethics.

James W. Brody, Esq. Mortgage Banking Practice Group Chair jbrody@johnstonthomas.com 415-246-3995

Roger Fendelman Principal

Marty Green Attorney

roger@garrishorn.com 636-399-0169

marty.green@mortgagelaw.com 214-691-4488 ext 203

James Brody actively manages all the complex mortgage banking litigation, mitigation, and compliance matters for Johnston Thomas. Mr. Brody’s experience centers on those legal issues that arise during loan originations, loan purchase sales, loan securitizations, foreclosures, bankruptcy, and repurchase & indemnification claims. He received his B.A. in International Relations from Drake University and received his J.D., with a certified concentration in Advocacy, from the University of the Pacific, McGeorge School of Law. He was a recipient of the American Jurisprudence BancroftWhitney Award. He is licensed to practice law in California and has been admitted to practice in front of the United States District Courts for the Central, Eastern, Northern, and Southern Districts of California. In addition, Mr. Brody has served as lead litigation counsel for numerous mortgage banking and commercial related disputes venued in both state and federal courts, in a direct capacity or on a pro hac vice basis, in AZ, CA, FL, MD, MI, MN, MO, OR, NJ, NY, PA, TN, and TX.

Roger Fendelman is a managing member of Garris Horn PLLC and CEO of Firstline Compliance. A mortgage compliance technology pioneer with more than 25 years of legal experience, Roger advises both mortgage originators and technology providers on compliance, technology, and automation challenges, with a focus on TILA, RESPA, QM, HOEPA, TRID, HMDA, ECOA and state consumer protection laws. For more than a decade, Roger served as the executive compliance leader of mortgage fraud and compliance technology innovator Interthinx and was the creative force behind PredProtect, one of the first cloud-based mortgage compliance automation solutions. Under Roger’s stewardship, the system became an industry standard for compliance, processing one million loans annually and earning a 2014 HousingWire AllStar award. He previously served in various capacities including compliance manager, processor and underwriter, providing him with an enhanced level of understanding for his clients’ day-today compliance needs.

Marty Green leads the Dallas office of Polunsky Beitel Green, one of the country's top residential mortgage law firms. Mr. Green is an accomplished attorney with more than 20 years of experience in the legal, banking and financial services industries. He is the former Executive Vice President and General Counsel for Dallas’ CTX Mortgage Co. and previously worked with the Baker Botts law firm in Dallas as Special Counsel. In his role as leader of the firm’s Dallas office, Mr. Green advises clients on the latest rules and regulations covering residential lending, in addition to building on Polunsky Beitel Green’s long tradition of delivering loan closing documents with speed and accuracy. Mr. Green is admitted to practice before all Texas state and federal district courts in addition to the U.S. Court of Appeals for the Fifth Circuit. An honors graduate of the University of Texas School of Law, he earned his undergraduate degree at Southern Utah University. Texas Monthly has selected him as a Super Lawyer multiple years.

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November 2020

The C-Suite

Wes Hunt

Founder and President Homestar Financial What do you think is the biggest challenge for the mortgage banking industry currently?

What do you find most rewarding about your job?

The initial challenge, as a result of the pandemic, was the larger percentage of employees working remotely.

At HOMESTAR, we have become a primarily remote workforce from an operations perspective and have not had any major issues as a result.

The most rewarding aspect is helping team members at HOMESTAR be successful and grow as well as driving growth and expansion of the company to the next level.

Additionally, I have always had a passion for helping individuals become homeowners while really and truly supporting our builder and realtor referral partners.

HOMESTAR is a “boots-on-the-ground” traditional company, therefore we’re highly engaged with the real estate and builder communities.

With the pandemic driving interest rates down further and the continued demand of housing, many companies along with HOMESTAR are experiencing record volume. The current challenge we face is the need for skilled underwriters, processors, closers, and industry professionals across the entire mortgage spectrum.

With a shortage of skilled industry professionals, we must rethink how we train individuals new to the industry in a remote environment.

What time do you get up?

7 a.m. or 7:15. I’m not an early bird.

What is the first thing you do in the morning?

I DocuSign any needed documents that the staff has for me. That’s my new routine in the remote environment. I have worked from home since March and that has changed some of my habits.

What is your mantra?

Be fair to individuals in all situations.

As a CEO, you’re faced with many different challenges as well as many different needs of people within your company. I try to find a balance that works for each one of those individuals; attempting to create fair and equitable solutions across the spectrum of the company.

What is on your desk?

A legal pad, because I can’t stop scribbling notes as I talk with people throughout the day. I also have a mouse and a keyboard.

What is your best habit?

Listening to another individual’s viewpoint and asking questions to ensure that I truly understand their goal or their need.

What is the last thing you do at night?

Watch the news.

What time do you go to bed?

About 10 p.m.

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November 2020

I have always had a passion for helping individuals become homeowners while really and truly supporting our builder and realtor referral partners.

The MORTGAGE BANKER Magazine

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November 2020

The C-Suite I am doing what I love with the people that I love.

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November 2020

Tanya Brennan

Managing Partner and President PhoenixTeam

What do you find most rewarding about your job?

What time do you get up?

I am doing what I love with the people that I love.

6:30 a.m.

What is the first thing you do in the morning?

Make coffee and check email.

What do you think is the biggest challenge for the mortgage banking industry currently in pandemic times?

What is your mantra?

There is always a silver lining.

COVID-19 has forced the mortgage industry to speed up the process of moving toward an even more digital customer experience. Whether customers are looking to refinance their mortgage or understand what options they have to retain their homes during times of financial difficulty, lenders and servicers need to focus on and offer a virtual and frictionless customer experience.

What is on your desk?

Three computers, a notepad for all to-dos, multiple pens, mobile, and stickies.

What is your best habit?

Notetaking.

What is the last thing you do at night?

Read.

What time do you go to bed?

11:30 p.m.

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November 2020

Education

Education & Training Calendar

Date

November 2020

Course Name

Type

October 26 – November 19

School of Loan Origination

Instructor Guided Online Course

October 28

Mortgage Servicing Call to Action and Post-COVID Challenges

Webinar

October 29

Building a Better Mortgage Process in the Wake of COVID-19

Webinar

November 2 November 16

Introduction to Mortgage Banking

Instructor Guided Online Course

October 26 – November 19

MISMO: Blockchain Mortgage Banking Legal and Regulatory Issues

Webinar

November 18

MAA Post-Election Update

Webinar

November 30 – December 21

School of Mortgage Banking I

Virtual Classroom

November 30 – December 18

School of Mortgage Banking III

Virtual Classroom

December 1 December 22

School of Mortgage Banking II

Virtual Classroom

To learn more about these and all upcoming offerings, visit https://www.mba.org/conferences-and-education/mba-education/upcoming-education

Conferences/Conventions

Instructor Guided Online Course (IGOL)

MBA Research Events

Classroom Course

Webinar

MISMO Events

The MORTGAGE BANKER Magazine

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November 2020

Other

WHITE PAPERS & WEBINARS

REGULATORY COMPLIANCE • RISK MANAGEMENT • OPERATIONAL EXCELLENCE

READ, WATCH & LEARN ...

ADVANCE YOUR KNOWLEDGE AND CAREER Click below for information and details on white papers, webinars and knowledge-based content

YOUR WHITE PAPER HERE

The MORTGAGE BANKER Magazine

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November 2020

Data Download OPTIMAL BLUE IS NOW PART OF

Top Origination Markets by Loan Volume Consolidated Metropolitan Statistical Area (CMSA)/ Metropolitan Statistical Area (MSA)

% of Lock Volume

MOM Growth

Avg Loan Amount (S)

Avg Rate

Avg FICO

Avg LTV

Purchase

Refi

1

Los Angeles-Long Beach-Anaheim, CA

6.21%

3.14%

481,880

2.928

758

62

18%

82%

2

Washington-Arlington-Alexandria, DC-VA-MD-WV

4.74%

-6.64%

419,138

2.818

753

75

32%

68%

3

New York-Newark-Jersey City, NY-NJ-PA

4.52%

2.13%

397,852

2.892

748

72

37%

63%

4

Chicago-Naperville-Elgin, IL-IN-WI

3.50%

-9.81%

271,307

2.917

749

76

37%

63%

5

Seattle-Tacoma-Bellevue, WA

3.01%

-3.16%

417,060

2.933

753

69

27%

73%

6

San Francisco-Oakland-Hayward, CA

2.97%

-1.65%

559,236

2.929

767

59

17%

83%

7

Boston-Cambridge-Newton, MA-NH

2.70%

-6.73%

403,314

2.881

755

68

28%

72%

8

Phoenix-Mesa-Scottsdale, AZ

2.70%

0.67%

292,224

2.981

743

74

34%

66%

9

Denver-Aurora-Lakewood, CO

2.61%

2.67%

359,459

2.903

755

70

27%

73%

10

San Diego-Carlsbad, CA

2.29%

4.32%

465,733

2.862

758

67

20%

80%

11

Dallas-Fort Worth-Arlington, TX

2.26%

-6.09%

293,034

2.943

740

77

43%

57%

12

Riverside-San Bernardino-Ontario, CA

2.18%

6.38%

336,417

2.940

736

74

30%

70%

13

Atlanta-Sandy Springs-Roswell, GA

1.79%

-1.61%

279,209

2.930

735

79

44%

56%

14

Minneapolis-St. Paul-Bloomington, MN-WI

1.72%

1.51%

284,625

2.876

755

75

36%

64%

15

Philadelphia-Camden-Wilmington, PA-NJ-DE-MD

1.69%

-7.49%

282,482

2.911

744

78

43%

57%

16

Houston-The Woodlands-Sugar Land, TX

1.60%

-5.61%

274,123

2.925

736

80

51%

49%

17

Miami-Fort Lauderdale-West Palm Beach, FL

1.45%

3.40%

319,946

2.983

735

76

47%

53%

18

Sacramento--Roseville--Arden-Arcade, CA

1.37%

-0.44%

358,779

2.956

751

70

28%

72%

19

Portland-Vancouver-Hillsboro, OR-WA

1.36%

-4.76%

344,074

2.947

755

71

32%

68%

20

Baltimore-Columbia-Towson, MD

1.27%

-5.09%

328,956

2.878

747

79

38%

62%

SOURCE: Optimal Blue, Plano, TX. Data is based on loans locked within Optimal Blue’s Digital Mortgage Marketplace platform.

Optimal Blue operates the leading Mortgage Marketplace Platform, connecting a network of originators and investors and facilitating a broad set of secondary market interactions. Nearly $2 Trillion of transactions are processed each year across the Optimal Blue platform. For more information, please visit www.optimalblue.com or email datasolutions@optimalblue.com.

Through actionable data and analytics, Optimal Blue enable mortgage lenders and professionals to visualize and track performance, compare profit margins, and assess the effectiveness of secondary marketing strategies.

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November 2020

Aug-20

Month-overmonth change

Year-over-year change

6.88%

-0.53%

99.22%

0.35%

-1.43%

-27.31%

6,000

-39.39%

-83.43%

Monthly Prepayment Rate (SMM):

2.70%

-0.95%

79.50%

Foreclosure Sales as % of 90+:

0.06%

0.37%

-96.88%

Number of properties that are 30 or more days past due, but not in foreclosure:​

3,679,000

-13,000

1,866,000

Number of properties that are 90 or more days past due, but not in foreclosure:​

2,366,000

116,000

1,922,000

Total U.S. loan delinquency rate (loans 30 or more days past due, but not in foreclosure):​ Total U.S. foreclosure pre-sale inventory rate:​ Total U.S. foreclosure starts:

Number of properties in foreclosure pre-sale inventory:​ Number of properties that are 30 or more days past due or in foreclosure:​

187,000

-3,000

-66,000

3,867,000

-14,000

1,801,000

12 Month Trend

Serious Delinquencies Improved in September for the First Time Since the Start of the Pandemic •

The number of seriously delinquent mortgages (90+ days) fell by 43,000 in September, marking the first such improvement in serious delinquencies since the start of the pandemic

•

More than 2.3 million homeowners – five times the number entering 2020 – remain 90 or more days past due, but not in foreclosure

•

The national delinquency rate fell in September to 6.66%, down from 6.88% the month prior

•

Early-stage delinquencies continue to show strong improvement, with rolls from current to 30-days delinquent, as well as the number of borrowers less than 90 days delinquent, having returned to pre-pandemic levels

•

Both foreclosure starts and foreclosure sales continue to remain muted given the widespread foreclosure moratoriums still in place

•

After a slight pull back in August, prepayment activity jumped above 3% in September for the first time in more than 16 years, fueled by record low rates and an elongated home buying season

Totals are extrapolated based on Black Knight’s loan-level database of mortgage assets. All whole numbers are rounded to the nearest thousand, except foreclosure starts, which are rounded to the nearest hundred.

About Black Knight As a leading fintech, Black Knight is committed to being a premier business partner that clients rely on to achieve their strategic goals, realize greater success and better serve their customers by delivering best-in-class software, services and insights with a relentless commitment to excellence, innovation, integrity and leadership. For more information on Black Knight, please visit www.blackknightinc.com.

Black Knight is a leading provider of integrated software, data and analytics solutions that facilitate and automate many of the business processes across the homeownership lifecycle.

Confidential, Proprietary and/or Trade Secret TM SM ® Trademark(s) of Black Knight IP Holding Company, LLC, or an affiliate.

All Rights Reserv ed.

The MORTGAGE BANKER Magazine 61 LLC. © 2019 Black Knight Data Analytics,

November 2020

Page 1 of 1

B2B

BUSINESS SERVICES DIRECTORY Proctor Financial provides comprehensive insurance products and service solutions for financial institutions.

While weaving compliance throughout all our applications and technologies, Proctor operates as an extension of our clients, where partnership meets innovation.

Amanda Bowers VP of Marketing abowers@pfic.com

Chenoa Fund is an affordable housing program provided through CBC Mortgage Agency (�CBCMA�), a uniquely created and organized government institution. CBCMA is a public-purpose driven governmental entity specializing in providing 100% financing for loans guaranteed by the FHA, with a focus on under-served borrowers. Our mission is to provide funding for affordable housing opportunities in communities nationwide. CBCMA partners with quality mortgage lenders on a correspondent basis to provide down payment assistance for qualified home buyers in the form of second mortgages and gifts. All assistance is provided in compliance with FHA guidelines.

Michael Whipple Vice President michael.whipple@ chenoafund.org

208.250.9132

A&S ELITE CONSULTING - Where your business is the focus of our business.

Shawna Adams, Managing Partner Co-Founder

We partner with clients to solve complex strategic problems, achieve operational objectives, and complete critical projects.

Our Elite team has successfully helped over 2000+ lenders select, implement, improve, and customize their LOS and lending technology. Collectively, we have beyond 200 years of experience in the mortgage industry. We are ready to help find solutions for your business!

wecanhelp@aselite.com

913.638.8247

Weiner Brodsky Kider PC is a Washington, D.C.-based firm with a national practice focused on compliance, regulatory, transactional and litigation matters related to financial services concerns. We represent a broad client base, from start-up businesses to Fortune 500 companies, throughout the United States.

Mitchel H. Kider Managing Partner

kider@thewbkfirm.com

202.557.3511

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November 2020

SPONSORS CORNER Many thanks to these sponsors for supporting our mission of bringing you a magazine dedicated to informing and educating mortgage banking professionals.

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PROMOTE AND ADVERTISE with