Fair Lending

If a loan is approved by FHA’s total scorecard and the DE Underwriter, can the lock desk refuse a pricing exception due to credit score risk outside of FHA guidelines?

Answer: While it is not a direct compliance violation, the implications of denying a pricing exception outside of written policy can be construed as Disparate Treatment under ECOA. If it is standard practice to grant exceptions and the lock desk refuses due to “risk”, then their policy should state that “these are the conditions where [...]

2019-07-23T10:42:04-05:00July 25th, 2019|

CFPB – BCFP Issues Annual Fair Lending Report – Dated December 4, 2018

Written By: Tammy Butler, Master CMB Never underestimate the CFPB and their priorities regarding mortgage lenders.  There are many uninformed ranters on the internet speaking of the demise of the bureau, and that couldn’t be farther from the truth.  Read this article to learn about the latest edition of the bureau’s fair lending report. Rule [...]

2018-12-10T08:35:35-05:00December 10th, 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|

CFPB Semi-Annual Update-Dated April 2018

By: Tammy Butler, Master CMB Two times per year, the CFPB issues a report to the President and Congress.  The updates are very telling as to the temperament and the direction of the CFPB.  This summary of the 56-page report is a good way to gauge the regulatory environment. Rule Synopsis: The CFPB had a [...]

2018-05-29T17:31:28-05:00April 9th, 2018|

Compliance – Lock Policy: As a correspondent lender, do we need to have a consistent pricing policy for lock extensions, or can this be flexible based on the investors we use?

Answer: This is an issue that most lenders must deal with as they progress from broker to correspondent.  As a correspondent, you are technically the lender, whereas as a broker, your investor was technically the lender.  The lender must demonstrate fair pricing policy to reduce the risk of disparate treatment.  This is why some adjustments [...]

2018-05-31T10:19:57-05:00February 22nd, 2018|