Compliance – Soft Pull vs. Hard Pull: Recently, our originators are requesting the ability to pull a soft pull on a client vs. a hard pull, as other lenders in the area are doing it, and it could be a cost-saving measure. Is this a regulatory issue?

Answer: QM/ATR only requires that the lender determine how they are going to validate credit history vs. telling you what type of report that you need. However, it will likely cause you regulatory issues under ECOA. When you issue adverse actions based solely on a soft pull, you do not have the entire picture of [...]

2018-11-25T20:10:14-05:00November 25th, 2018|

Facebook vs. HUD Show Down! NEW Social Media Ad Checklist!

Written By: Tammy Butler, Master CMB Social media marketing is growing, and as it does, Washington DC and the state AGs are taking note.  Facebook is in hot water with HUD over the filters companies or other licensed professionals can select when targeting their ads, because HUD believes these filters are a violation of the [...]

2018-09-10T12:41:03-05:00September 10th, 2018|

Has Fair Lending Been Neutered?

By: Tammy Butler, Master CMB Fair Lending Perspectives-The CFPB’s Latest Decision If you have anything to do with Fair Lending in your company, you have no doubt heard the news about the recent change at the CFPB with regard to Mulvaney’s decision to strip the Fair Lending Office of enforcement duties and move those duties [...]

2018-06-01T13:09:18-05:00February 8th, 2018|