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6-15-2010
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Mortgagee Letter 2010-20 re-states previous guidance - FHA
Approved Mortgagees can originate loans through TPOs. There
will be no tracking by FHA of TPO until approximately September 2010.
After 9/2010, TPOs will have separate IDs, allowing lenders to track TPO
performance. Existing mini-eagles will be able to access
Neighborhood Watch until 1/1/2011, thereafter no access.
4-14-2010 - Long
awaited guidance from HUD on TPO (broker/correspondent) origination
procedures. Click
here to read entire
text.
Executive Summary:
Mortgagee Approval
- Net worth increases to $2,500,000 in 2013, 2,000,000 by 2012, plus 1%
of volume over $25,000,000.
- Temporary Accommodation made for "Small Business Lenders" to $500,000
minimum net worth - through end of 2010.
- Authorized Agents (In Principal/Authorized Agent Relationship) must
have DE underwriters beginning 2011
TPO - Broker Approval
- Brokers (referred to as TPO) Handled through Sponsor directly - NO FHA
guidance on standards, but must meet all FHA criteria
- FHA Lender must monitor all activities for compliance
- FHA Lender is responsible for ALL actions of TPO
- Current brokers approved through 1/1/2011
- No Stated Net Worth Requirement
- No Stated QC Process Requirement
TPO - May No Longer Table Fund - Effective 1/1/2010
3-29-2010 - FNMA
Announces more rigorous quality
control requirements. Non-compliance will result in loan
repurchases.
3-4-2010 -
Mortgage Broker Renewal Extended - As proposed in a November 30, 2009, proposed rule (74 FR 62521), HUD is
seeking to eliminate FHA approval for loan correspondents. Because this
rulemaking is still in process and a final rule has not yet been issued,
FHA is extending the deadline for the submission of audited financial
statements for loan correspondents seeking renewal of their FHA lender
approval for 2010. For loan correspondents with a fiscal year end of
December 31, and that would ordinarily be required to renew their FHA
approval by March 31, 2010, HUD is providing these lenders with an
additional 30 days in which to submit their audited financial
statements. These loan correspondents must continue to comply with
existing requirements for the submission of their Annual Certifications
and renewal fees, but will be given until April 30, 2010, to submit
audited financial statements. Again, the deadline for the submission of
the Annual Certification and renewal fee has not been changed. Loan
correspondents that do not complete their renewal in accordance with the
deadlines as specified above will no longer be FHA-approved as of the
effective date of the final rule that follows the November 30, 2009,
proposed rule.
1-14-2010 -
Correspondents are reporting that HUD is still accepting broker
(mini-eagle) applications.
11-30-09 - HUD
officially has eliminated the correspondent (broker) approval process.
Current correspondents will not be renewed. This administrative
ruling takes effect in 30 days under expedited rulemaking authority.
Going forward, wholesale lenders will be responsible for assuring that
brokers comply with FHA requirements and the requirements of the SAFE
Act.
11-10-09 -
2 More lenders fined or sanctioned after failing to maintain
a quality control plan
9-18-09 - HUD Eliminates
Broker (Correspondent) Approval and Increases Lender Net Worth
Requirement - FHA announced on
www.hud.gov that it would no longer approve mortgage brokers
(correspondents). Approved lenders will now approve brokers, just
like FNMA/FHLMC. In addition, HUD increased the minimum net
worth requirement to $1,000,000. These changes are being
implemented in the rulemaking process and should take effect in 90-180
days pending comment.
4-15-09 - FHA/HUD SWAT
Teams - It is not an urban myth. FHA examiners are
appearing, unannounced, at the offices of HUD approved mortgage brokers
and lenders demanding access to files. We have seen this in
Houston, Dallas, Denver, Los Angeles, Atlanta, Baltimore and Tampa.
The first thing requested - "please show us your
quality control plan."
2-24-2009 - It
is becoming clear that the Mortgage Broker business of the past is over.
1) HVCC (Home Valuation Code of Conduct)
eliminates the broker's
role in directing the selection or ordering of the appraisal - brokers
can no longer compete on the basis that there is better chance of
obtaining the value. 2.) PMI no longer accepting broker ordered
PMI and instituting higher credit standards and premiums for Third Party
Originated applications 3.) RESPA Reform eliminates fee packing
with the new Good Faith Estimate process requiring that the broker state
the specific dollar amount of compensation received from all sources and
not allowing that number to change after application. The
solution? Become a lender.
1-21-2009 -
Information Security -
FTC Files Complaint
against Nevada Mortgage Broker
12-31-2008 - FHA
Relevant Again - insures over 25% of all mortgages made in the US in
2008. In 2009, with streamline refinance programs that don't
require an appraisal, the ability to cash out at 95% LTV, no saved down
payment, liberal income, asset and credit qualifying standards, FHA
insured residential mortgages have become the leading affordable lending
program.
September, 2006
- New Mortgagee Approval Guidelines - FHA
revised its quality control guidelines to include all aspects of
mortgagee operations. Previously, the fraud detection, random
audit selection and review process were the only components reviewed.
FHA is suspending applications and
renewals to require that the mortgagee incorporate these factors: For supervised lenders and sponsored brokers
evidence of controls in the origination, processing, underwriting, funding and human resources
management components must be included in the quality
control submission. Required disclosures, checking disbarred
mortgagees, affirming date of last transfer, and mortgagee licenses are
prominently posted, Be aware that branches will be inspected in a
physical audit. Particularly attention is paid to the hiring of
1099 contractors as employees.
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