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Loan Processing Guidelines and Quality Control Plans for Licensed MLO
● All Mortgage Loan Originators (MLO’s) Must Take Two Webinars on Blink Prior to Starting
Any Loans
● In addition, if you have never processed a loan before each lender has training that must
be completed before starting a loan.
● Once the items above are completed and you need additional training, please see this link
for Mentoring
Purpose
The purpose of Real Estate eBroker Inc Loan Processing Guidelines and Quality Control Plans for
Licensed MLO (“Plan”) is to evaluate and monitor the overall quality of mortgage loan production for
all types of loans. The Plan is to verify the existence and accuracy of legal documents, credit
information, and property appraisals contained in each loan transaction file. It assures that:
Our loan standard operating procedures (SOP) comply with all applicable laws and regulations;
Our policies and standards are known and adhered to by our personnel;
Our SOP is revised to reflect any/all applicable changes to laws and regulations, our personnel are
informed of the changes, and our employees are held accountable for any performance error;
Prompt and effective corrective actions are taken and documented when deficiencies in loan
origination or underwriting are identified and our personnel are informed when deficiencies are
found; and Procedures exist to expand the scope of quality control reviews when fraudulent
activities or patterns of deficiencies are identified.
Table of Contents
Activity not allowed with the REeBroker Group
Anti-Steering
Anti-Steering Disclosure
Application Processing (Blink system)
Appraisal
Approved Lenders & Fees
Compliance with 24 hours
Closing Disclosure
Credit
Down Payment Assistance
High-Cost Mortgages and HOEPA Compliance
Licensing Requirements
Loan Office Policy
Loan Estimate
Loan Denial
Loan Underwriting
Marketing Guidelines
Mortgage Terms
NMLS Policy Guidebook
Origination Fees
Pre-Approval
Privacy Policy Requirements
QC Plan (Pre and Post Funding Audits)
Record Retention
Referrals
Steps to Processing a Loan
Summary of the Loan process for new MLO
Timeline for Disclosures
Tolerances
VA Loan Information
Warnings & Red-Flags for Security Identity Theft
Working From Home - Guidance
Unauthorized Activity
Activity that is NOT allowable under the REeBroker Group
● Mortgages with balloon payments
● An MLO cannot represent a client on a FHA, USDA or VA loan and also represent them on a
real estate transaction that involves that loan.
● Servicing of any loans
● Collect any fees or commissions directly from a client or lender
● Timeshare transactions
Note: All REeBroker Group MLO’s must refer their personal transactions to another MLO.
Anti-Steering
Anti-Steering Disclosure
● The Anti-Steering information is to be provided with the Anti-Steering Disclosure.
● The information can be acquired via the lender(s) you are using and should show the
different interest rates, features, fees, etc.
Example:
Appraisal Report
PLEASE NOTE: DO NOT ORDER APPRAISAL UNTIL THE BUYER HAS SIGNED THERE DISCLOSURE
PACKET FROM THE LENDER STATING THEY ARE READY TO MOVE FORWARD WITH THE LOAN.
There are two state (California) disclosure requirements: (1) the lender must send a notice to the
borrower informing the borrower of the borrower’s right to receive a copy of the appraisal; and (2)
the broker must send a copy of the appraisal to both the lender and the borrower. There are two
federal disclosure requirements. One disclosure is required by the Equal Credit Opportunity Act
(ECOA) and another will be required by the Truth-In-Lending-Act (TILA). The same appraisal notice
can be used to satisfy both the ECOA and TILA requirement.
Link to Advance Fee Notice
Application Processing (Blink)
See Step-by-Step guide for taking and entering into the Blink system.
Approved Lenders
List of current approved Lenders
If you or your client have a preference to use a lender that is not already on list, please allow up to
30 days for lender registration, and contact [email protected].
Shop the Best Rates for Your Client - MLO Instructions for shopping loan products
A good loan originator should ask plenty of questions. To find the right loan and get the borrower
the best rate, they’ll need to know as much as possible.
1. Employment situation: Loan originators need an understanding of borrowers income. If theborrower is a W2 employee, things are relatively simple. But your work history, bonusincome, and other factors can complicate matters. For self-employed individuals or thosewho work as independent contractors, it’s especially important to discuss the details of theiremployment—how long they have been in business, the types of deductions they use, andmore.
2. The property borrower is buying: Depending on what property the borrower is buying, theloan options may be limited. It’s essential to discuss the details about any property with yourborrower. For example, condos with certain characteristics might not be eligible for someloan programs—but other options are always available. If a borrower does not have aspecific property picked out then good to discuss what options the borrower will haveavailable to them.
If property is not identified put “To Be Determined (TBD)”
3. Know Your Loan Options
Once a lender is chosen the borrower(s) will receive a notification from the lender to access
the lenders system and complete their consent to proceed with the loan.
As MLO, you may have numerous loan programs available to choose from, and a skilled
originator will fit all of the puzzle pieces together to find the best loan that the borrower
needs. Your options depend on:
1. Borrower’s credit history and income
2. Size of down payment borrower plans to make
3. What type of property borrower wants and location (restrictions?)
4. Borrower in the service or first time home buyer (qualify for VA or FHA?)
5. Borrower’s existing debt and payment amounts
4. Use the Mortgage Shopping Worksheet and fill out (below) using our company’s list of
approved lenders:
The disclosure of the agent’s dual role shall be made within 24 hours of becoming both the
sales broker and loan broker on the same transaction.
Loan Shopping Worksheet
https://www.consumer.ftc.gov/articles/pdf-0104-mortgage-shopping-worksheet.pdf
Compliance
Activity Reporting
MLO is required to report all his/her real estate activities to the Broker within 24 hours of a LoanEstimate being generated or as soon as a Loan Denial letter is sent out. Proper reporting is when theAssociate-Licensee opens a new transaction, makes changes, uploads documents, or writes notes inthe transaction file on the Broker’s online system.
You will need to create Loan Transaction by using the My Transaction link on your agent homepage:
Agent Home (reebroker.com) > Add New Transaction
Select OPEN for the Transaction Status
Select LOAN for Transaction Type
The following information is required to save all loan files:● Property Address● Borrower(s) names● Is this file a Purchase or Refinance● Lender Name● Loan Amount
Documents required when the Loan transaction is created:● Loan Application● Loan Estimate● Credit Invoice
Areas of Compliance Focus
Application DisclosuresCopies of Signed Documents (Mailed Applications):● This disclosure only applies for mailed applications.
● There is no signature or date requirement.
Addendum to the Uniform Residential Loan Application (URLA) FNMA 1003 (Credit MarriedApplicant Disclosure):
● Only applicable if any of the borrower(s) are married.
Addendum to Residential Mortgage Loan Application (a/k/a Domestic Partner Disclosure):● If separate disclosure from 1003, verify dates prior to close.
● Only required for unmarried borrowers.
The Housing Financial Discrimination Act of 1977 Fair Lending Notice● Must be dated when submitted to UW for broker loans.
● Must be signed by Borrower.
Hazard Insurance Disclosure:● Verify dated prior to closing.
Marital Rights
CALIFORNIA IS A COMMUNITY PROPERTY STATE.NON-BORROWING SPOUSES ARE REQUIRED TO SIGN THE MORTGAGE, CD AND RIGHT OFRESCISSION (IF APPLICABLE). FOR NON-COMMUNITY NON-HOMESTEAD PROPERTY,NON-BORROWING NON-TITLED SPOUSE DOES NOT NEED TO SIGN BUT WE NEED TO HAVEESTABLISHED WITH CERTAINTY THAT PROPERTY IS SOLE AND SEPARATE PROPERTY OF SPOUSE. NEEDTO REQUIRE AN INTERSPOUSAL GRANT DEED FROM NON-BORROWING NON-TITLED SPOUSE INORDER TO EXTINGUISH THE COMMUNITY PROPERTY RIGHTS AND HOMESTEAD RIGHTS OF THENON-BORROWING NON-TITLED SPOUSE. OTHERWISE, LIEN IS VOIDABLE.
Closing Practices
California is a dry funding state. Borrower shall not be required to pay interest on principal for morethan one day prior to the date loan proceeds are disbursed. The title company must order funds nomore than one day before Borrower can close.
Closing Disclosure
A Closing Disclosure is a five-page form that provides final details about the mortgage loan you have
selected. It includes the loan terms, your projected monthly payments, and how much you will pay in
fees and other costs to get your mortgage (closing costs).
Use this tool to double-check that all the details about your loan are correct on your Closing
Disclosure.
Credit
MLO Access to Lenders, Credit and additional accounts
Please be advised that the set-up for credit access and lender logins could take up to a week
depending on lender and credit company processing times. You will be notified when we advise the
affiliate companies that you have been added as an MLO at which time you will be given access to
our list of lender contact information. You are responsible for confirming that all information is
correct on each account. Please be advised that some accounts may require additional setup steps
from the MLO directly. Feel free to contact Paige at [email protected] if you have any
questions.
Credit can be pulled directly from the Blink system. If you experience any issues please contact UWM
in order to complete the application you will need the borrower’s authorization to pull credit. The
links below are required to be provided to the borrower to sign prior to pulling credit.
1.Borrowers Sign Advance Fee Notice
2.Provide link to smart pay for credit report from CIC or use the blink system credit system that is
linked to your CIC account.
Form 1003
Blink allows you to submit the 1003 application directly to UWM or to download it and send it to
another lender.
Final signed application should include
● Employment/Self Employment Information
● Income (at least 2 years) Information: W2, Profit & Loss, Pensions, Social Security, Public
Assistance, Child Support, and Alimony
● Assets Information: Bank accounts, Real Property, Investments/Retirement Accounts,
Proceeds from the Sale of the Current Property, Gifted Funds.
○ Check lender requirements for seasoning of Gifted Funds
○ Gift Letter must include:
■ Client's name as recipient■ Donor's name, address, phone number, and relationship to the client■ Amount of the gift and the date the funds were/will be transferred■ Donor's statement that no repayment is expected■ Donor's signature (Can be e-signed through DocuSign or alternative source)■ Contain language certifying the funds were not obtained from an
unacceptable source (including the seller, real estate agent/broker; builder,loan officer or any entity associated with them).
■ Client must e-sign or wet-sign and date the gift letter
● Debt Information: Current Mortgage, Liens, Alimony, Child Support, Car Loans, Credit Cards,
and Real Property.
● Property Information - if for a purchase can be “To Be Determined (TBD)”
● Mortgage/Rent statement
● Credit Explanation Letters/Bankruptcy Papers: Collections, Foreclosures, Delinquencies, etc
● If there is an HOA or Solar Company they may require additional time for processing. The
MLO should obtain the company information as soon as possible so the party responsible
(MLO, Lender, Escrow or Title, whomever assumes the responsibility for ordering the
information starts at the start of the loan being processed.
Down Payment Assistance
Please log into www.car.org to see this information
https://www.car.org/marketing/clients/deletedownpaymentresource for sources of down payment
assistance
High-Cost Mortgages And HOEPA Compliance
High-cost mortgage loans or HPMLs come with their own set of regulatory requirements unique from
other mortgage lending requirements imposed by RESPA and Regulation Z.
What is an HPML?
Regulation Z defines a higher-priced mortgage loan as a closed-end consumer purpose loan that is
secured by the borrower’s principal dwelling. It’s all that’s mentioned so far, PLUS:
● It has an APR that exceeds the average prime rate offer for a comparable transaction as of the
date the interest rate is set by: 1.5 percent or more for a first-lien loan in a principal amount
that doesn’t exceed eligibility for purchase by Freddie Mac
● 2.5 percent or more for first-lien loan in a principal amount that exceeds the maximum
purchase eligibility for purchase by Freddie Mac OR
● 3.5 percent for a subordinate-lien loan
Reverse mortgages, construction-only loans, bridge loans with a term of 12 months or less, and HELOCs
are exempt.
What are the key requirements?
● The borrower’s ability to repay matters with this type of mortgage loan. The Home Ownership
and Equity Protection Act or HOEPA prohibits you from making an HPML without considering this
point.
● How is repayment ability determined? By looking at current and expected income, employment,
assets other than the collateral, current obligations, including mortgage-related obligations.
Also, full interior appraisals must be completed, and they must be performed by a certified or licensed
appraiser. If the property is a “flipped” property, a second appraisal is required but at no charge to the
borrower. The regulation considers a “flipped” property as one that is purchased from a seller who
bought the property less than six months before and the purchase price is either 10 percent more, if the
seller bought the property within the past 90 days, or 20 percent more, if the seller bought the home in
the past 91-180 days.
Make sure your procedures and processes update the exemption threshold amount, which for 2021 is set
at $27,200.
Regarding disclosures, at application, the Equal Credit Opportunity Act notice must be provided. Make
sure that a free copy of any written appraisals you obtain are provided to the borrower at least three
business days before consummation.
Except in certain circumstances, lenders are prohibited from charging prepayment penalties. And, make
sure you didn't structure closed-end mortgage loans as open-end lines of credit to avoid these
requirements; the rules specifically prohibit it.
Escrow accounts:
Regulation Z requires the creation of an escrow account for a minimum of five years for property taxes,
homeowner's insurance, and other insurance obligations for a first-lien HPML secured by the borrower’s
principal dwelling. The borrower is permitted to request the cancellation of the escrow account after the
five-year period. Regulation Z provides requirements for this process. And, a couple of exemptions exist
from these requirements.
Licensing Requirements for Certification
1. Before proceeding to work with a client confirm your MLO license is properly placed under
the Real Estate eBroker Inc. NMLS ID:297152 brokerage license by checking this link
https://www.nmlsconsumeraccess.org/
Note: Use the same exact name as your real estate and mlo license.
Note: There will be a charge for any mlo's that have already been registered with another
company prior to coming to REeBroker Group. $30 for the NMLS and $5 for the broker to
process the payment. $35 total charge. MLO's that were never registered before with a
company are not charged this fee.
If your employment information is not appearing as stated below please contact
[email protected] prior to proceeding further.
_______________________________________________________________________
2. Confirm you have completed your RE866 with the DRE (sample below) by emailing a
screenshot of your completed loan activity conducted screen and your DRE license showing
you can conduct loan activity.
https://secure.dre.ca.gov/elicensing/nmls.asp
___________________________________________________________________
Loan Office Policy
Must be read and reviewed by all Mortgage Loan Originators (MLO).
Loan Division Office Policy
Loan Denial - Notifications
https://www.consumerfinance.gov/rules-policy/regulations/1002/Interp-9/#9-a-1-Interp-4
Timing of notice - when an application is complete. Once a creditor has obtained all the information
it normally considers in making a credit decision, the application is complete and the creditor has 30
days in which to notify the applicant of the credit decision. If a borrower is unresponsive for 90 days
a denial letter should be issued.
Notification of approval. Notification of approval may be expressed or by implication. For example,
the creditor will satisfy the notification requirement when it gives the applicant the credit card,
money, property, or services requested.
A REeBroker Group loan file should be created when a Loan Denial is sent out.
Reasons for Denial
● Denial for incompleteness. When an application is incomplete regarding information that the
applicant can provide and the creditor lacks sufficient data for a credit decision, the creditor
may deny the application giving as the reason for denial that the application is incomplete.
The creditor has the option, alternatively, of providing a notice of incompleteness under §
1002.9(c).
● Denial for reasons other than incompleteness. When an application is missing information
but provides sufficient data for a credit decision, the creditor may evaluate the application,
make its credit decision, and notify the applicant accordingly. If credit is denied, the
applicant must be given the specific reasons for the credit denial (or notice of the right to
receive the reasons); in this instance missing information or “incomplete application” cannot
be given as the reason for the denial.
● Denial of a telephone application. When an application is made by telephone and adverse
action is taken, the creditor must request the applicant's name and address in order to
provide written notification under this section. If the applicant declines to provide that
information, then the creditor has no further notification responsibility.
Length of counter offer does not require a creditor to hold a counteroffer open for 90 days or any
other particular length of time.
Counteroffer combined with adverse action notice. A creditor that gives the applicant a combined
counteroffer and adverse action notice that complies with § 1002.9(a)(2) need not send a second
adverse action notice if the applicant does not accept the counteroffer. A sample of a combined
notice is contained in form C-4 of appendix C to the regulation.
Note: a denial letter or notification will need to be issued on all files that are not approved or the
borrower backs out.
Template Loan Denial Letter
You may also pull a loan denial letter from your CIC Credit account:
https://cic.meridianlink.com/custom/login.aspx
If the following six items are given for an application then a Denial Letter is required (if applicable):
Consumer’s name, income and social security number (to obtain a credit report), the
property’s address, an estimate of property’s value and the loan amount sought.
Microsoft Word - Credit Link Quick Reference Card.doc (credit-link.com)
All Cancelled/Denied Loan Transactions must be recorded in the REeBroker Group agent portal.
Create a Loan Transaction > Upload all applicable documents > Change status to “Request to Cancel”
Checklist for Cancelled or Denied Loans
Loan Estimate
Delivered or placed in the mail to borrowers no later than three (3) business days after the receipt of
the consumer’s application. The Loan Estimate includes closing costs, the interest rate and monthly
payments (principal, interest, taxes, and insurance). See this example
https://www.consumerfinance.gov/owning-a-home/loan-estimate/
Loan Underwriting
Some steps listed below may be required for MLO to initiate, each lender has their own requirements
● Order credit report (if not previously completed)
● Begin Verification of Employment (VOE) and bank deposits (VOD)
● Order property inspection (if applicable)
● Order property appraisal
● Order title search
Interest Rate Lock
Policies and procedures regarding locking an interest rate, including exceptions that may be applied;
If the interest rate was locked, determine whether the creditor provided a revised Loan Estimate,
including the revised interest rate, any points paid to reduce the interest rate, lender credits, and any
other interest rate dependent charges and terms within three business days after the rate has been
locked.
Provide Lock-in Agreement & Rate Sheet for that day
Marketing Guidelines
All marketing materials must first be approved by [email protected]
Mortgage Terms
Glossary of all Loan Terms:
https://reebroker.com/Docs/Library/Tree/Loan%20Documents/Loan%20Term%20Acronyms%20-%2
0Sheet1.pdf
NMLS Policy Guidebook - link to guidebook
Origination Fees
https://www.fidelityedesk.com/Uploads/21/06/12106/gallery/mosaic_tax_impounds0215.pdf
Example of a Final Refinance Statement
TRID Guide
Example of a UWM Summary
What Are Mortgage Fees and Closing Costs?
Most mortgage fees fall under the umbrella category of "closing costs." Closing coststypically equal 2% to 5% of the home sale price and are paid when you sit down at the tableto sign the final documents and transfer ownership.
The following fees are some of the more common expenses charged as part of the closing costs. Thislist is not exhaustive, and depending on the nuances of your home purchase, you may be responsiblefor paying other fees as well.
● Appraisal Fee. This covers the cost of having a certified appraiser determine the value ofthe home you are purchasing. An appraisal ensures the value of the home is enough tocover the loan.
● Home Inspection Fee. This fee covers a professional home inspection, which is critical tomaking sure you aren't buying a home with unknown problems. Many lenders require aninspection, but either way, it's smart to get one to protect yourself and your investment.
● Loan Origination Fee. You pay this fee to the lender for the costs of considering andorganizing your new loan. This fee may encapsulate other fees like application andunderwriting, so make sure to ask what it includes so you don't get double-charged forany services.
● Application Fee. You may have to pay multiple application fees when getting a mortgage.These fees may be included in your loan origination fee, so read your loan documentscarefully and check with your lender if you think you may have been double-charged.Application fees may also be charged if you need to apply for private mortgage insurance(PMI), which happens when you are putting down less than a 20% down payment.
● Credit Report Fee. At some point in the mortgage process, your lender will check yourcredit. This fee covers their cost to obtain a copy of your credit reports and scores.
● Recording Fee. This fee covers the local government's charge to confer and record yournew property's deed.
● Document Preparation Fee. This fee covers the preparation of the many documents thatwill be signed and organized at your closing. Umbrella fees charged by the lender may alsoinclude this fee, so pay close attention if you see this pop up.
● Title Insurance Fee. This fee is paid to a title insurance company and will cover the costassociated with insuring the transfer of the deed to your name.
These fees can range from hundreds to thousands of dollars and cover expenses that are standard tothe homebuying process. If you don't know about them in advance, they may come as a shock. Butnearly every homeowner pays these fees, and in many cases they are for services critical topurchasing a home. Just make sure you're not paying them twice, and ask your lender if you areconfused by any unfamiliar fees.
Note on waiving impounds: Mortgage Insurance and flood Insurance, if required, must always beescrowed even if the borrower elects to not escrow for their taxes and or insurance.
Pre-Approval
Buyer Pre-Qualification/Approval & Down Payment
Loan disclosure documents are sent electronically to the borrower and can be eSigned, viewed,
saved, and printed from the lenders electronic document portal.
Checklist sample
https://www.lenderlive.com/Portals/18/CLDocs/07.20.16%20%20Loan%20File%20Submission%20C
hecklist1.pdf?ver=2016-07-20-111723-923
Spreadsheet of all required mortgage forms for REeBroker Group MLO:Refi ChecklistNew Purchase Checklist
When the borrower completes certain steps the lender is requesting, you should be receiving email
updates from the lender accordingly or you may have to log into their portal daily for updates. Check
with the lender regarding their notification system.
A mortgage loan disclosure statement is required in a transaction in which a broker is arranging a
loan. However, for loans governed by the Real Estate Settlement Procedures Act and the Truth in
Lending Act, if the broker provides all disclosures that those Acts require, then the broker does not
need to provide a mortgage loan disclosure statement. This exception only applies to loan amounts
that are $30,000 or more for senior liens, or $20,000 or more for junior liens. Finally, a DRE licensee
advisory revised 12-01-2015
(http://calbre.ca.gov/files/pdf/adv/MLDS%20and%20Loan%20Estimate%20Advisory.pdf), states that
this exception also applies if the broker provides the Loan Estimate form that is compliant with the
TILARESPA Integrated Disclosure (see section XVIII below), along with a separate disclosure that
includes a statement that the Loan Estimate does not constitute a loan commitment and that the
borrower may check the license status of the broker and/or loan officer by calling the Bureau of Real
Estate’s license information telephone number at 1-866-373-4542 or visiting CalBRE’s Web site at
www.calbre.ca.gov.Who must disclose/who must receive disclosure Real estate brokers must make
the disclosure and deliver it to the borrower. (B&P Code § 10240(a))
Disclosure of material changes Any material changes to the costs, expenses or terms of the loan
should be disclosed to the borrower(s) in a timely manner. (B&P Code § 10176(a), 10176(c)).
Exemptions from disclosure requirement In a federally regulated residential mortgage loan
transaction in which the principal loan amount is $30,000 or more for a senior lien or $20,000 or
more for a junior lien, a broker satisfies the disclosure requirement if the borrower receives: (a) a
“good faith estimate” that satisfies the requirements of the Real Estate Settlement Procedures Act,
and that sets forth the broker’s real estate license number and a clear and conspicuous statement on
the face of the document stating that the “good faith estimate” does not constitute a loan
commitment; (b) all applicable disclosures required by the Truth in Lending Act; Also, please see the
“Summary” section above for exemption for TILA-RESPA Integrated Disclosure.
Privacy Policy Requirements
GLBA requires each financial institution to develop a privacy policy that clearly and conspicuously
accurately reflects the institution’s privacy policies and practices at the time of establishing the
customer relationship.
The privacy policy developed by the financial institution must accurately address the following
safeguard precautions and procedures:
1. Ensure safety and security of customer records and information through processes and
procedures;
2. Protect against anticipated threats or hazards;
3. Prevent unauthorized access that could substantially harm or inconvenience any customer;
4. Assign one or more employees to oversee the program;
5. Conduct risk assessments to test adequacy of program;
6. Require vendors to protect confidentiality of information;
7. Perform due diligence prior to vendor selection;
8. Contractually require provider to adhere to privacy policy and notify you of breaches;
9. Monitor and audit provider’s privacy efforts;
10. Access to facilities (check-in with receptionist, badges, key cards and so on);
11. Access to computer systems (passwords, requirement that passwords be periodically reset,
access limitations based on job duty);
12. Internet and email security (encryption);
13. Clean desk policy; and
14. Safe preservation and disposal of records (electronic and hard copy).
Subpart A of §1016 contains model privacy and opt out notices. This section states that the model
privacy form is a standardized form, including page layout, content, format, style, pagination, and
shading. Financial institutions seeking to obtain the safe harbor through use of the model form may
modify it only as described in the instructions in the Appendix.
Examiners have found that companies failed to accurately complete the information required to be
disclosed in the privacy policy form.
QC Plan (Pre and Post Funding Audits)
Audit information, checklists, and corrective actions: Click Here
Record Retention
● Creditors and loan originator organizations retain records related to loan originator
compensation and compensation agreements for three years after the date of payment.
● Reporting of your activity is done by creating a Loan Transaction file in your “My
Transactions” section of your agent homepage.
● Information that will be required when creating your file:
Borrowers names
Property address
Lender Name
Type of loan
Referrals
No referral fees. No person shall give and no person shall accept any fee, kickback or other things of
value pursuant to any agreement or understanding, oral or otherwise, that business incident to or
part of a settlement service involving a federally related mortgage loan shall be referred to any
person.
What is a Referral?
1. A referral includes any oral or written action directed to a person which has the effect of
affirmatively influencing the selection by any person of a provider of a settlement service or
business incident to or part of a settlement service when such person will pay for such
settlement service or business incident thereto or pay a charge attributable in whole or in
part to such settlement service or business.
2. A referral also occurs whenever a person paying for a settlement service or business incident
thereto is required to use (see § 1024.2, “required use”) a particular provider of a settlement
service or business incident thereto.
What is a “thing of value”?
https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1024/14/#c
No person shall give and no person shall accept any portion, split, or percentage of any charge made
or received for the rendering of a settlement service in connection with a transaction involving a
federally related mortgage loan other than for services actually performed. A charge by a person for
which no or nominal services are performed or for which duplicative fees are charged is an unearned
fee and violates this section. The source of the payment does not determine whether or not a
service is compensable. Nor may the prohibitions of this part be avoided by creating an arrangement
wherein the purchaser of services splits the fee.
Steps to Processing a Loan
Blink Guidelines and How to Process a LoanNote: You will need to sign in with your UWM credentials to access this manual.
List of documents
https://reebroker.com/Docs/Library/Tree/Loan%20Documents/Buyer%20Pre-Qualification_Approval
%20&%20Down%20Payment.pdf or
https://reebroker.com/Docs/Library/Tree/Loan%20Documents/Mortgage%20Loan%20Application-C
hecklist%20%20REeBroker%20Group%20(2).pdf
Obtain all information
Solar
HOA
After the borrower fills in the application, sign the advance fee form and give them your SmartPay
link for credit.
CIC (credit pull) informationhttps://www.ciccredit.com/wp-content/uploads/2018/06/fnma_and_fmac_reissue_requirements.pdfNote: Ensure that your account is set to “manual” and not automatic credit pulling information.CIC Credit Fee Sheet
Advance fee
https://reebroker.com/Docs/Library/Tree/Loan%20Documents/Loan%20Forms/Advanced%20Fee%2
0Disclosure%20Fillable%20(1)%20(2).pdf
Fannie Mae Selling Guide
Questions call Fannie Mae Help Desk 800-232-6643
Freddie Mac Selling Guide
Question call Freddie Mac Help Desk 800-373-3343
Summary of the Loan process for new MLO
The mortgage application process starts when pre-approved borrowers get a real estate purchase
contract. Or if borrowers are homeowners, they give the mortgage loan originator the heads up to
start the refinance mortgage process.
● The mortgage loan originator will send out the official mortgages disclosures after borrowers
have completed their loan application and sent documents
● The lender will run the mortgage application file through Automated Underwriting System
for an automated approval
● Once borrowers provide the signed mortgage loan application and provide documents
requested such as the following:
○ two years tax returns
○ two years W-2s
○ two months bank statements
○ current paycheck stubs
○ other documents needed
● The mortgage loan application gets processed by a mortgage processor so it can get
submitted to a mortgage loan underwriter
● The mortgage underwriter is the person that decides whether a loan applicant gets
approved or not
● The underwriter is the person who issues a clear to close (CTC)
● A clear to close is when the lender is ready to fund the mortgage loan
● Closing docs get prepped after the underwriter issues the CTC
● Please note that the broker does not send commission demands to escrow for loan
transactions because escrow does not usually accept them. The full Origination
Compensation will come to the broker’s office directly and we will pay the MLO according to
the instructions in their transaction file once the file is accepted. We will also require the
copy any paid invoices that will be reimbursed to the agents.
Note regarding Assets:
● Gift Funds: Provide evidence that gift funds have been deposited into the borrower's
account and were withdrawn from the donor’s account. Asset statements should indicate
account holder name information .
● Verify clearance of earnest money deposit. Needs borrower's name on statement.
Below are 3 alternative ways to obtain VVOE:
1. The employer can wait for UWM’s VVOE (Verbal Verification Of Employment) team to reach
out to the employer and hope they get through (slowest option)
2. Your employer can call UWM at 800-981-8898, ext. 3550 and provide your loan number.
(This must happen from a company phone number)
3. The employer can email, from the company’s email, verifying the following information:
SUBJECT: (Last name, First Name, Loan Number)
The body must contain the following:
Is Borrower Name actively employed and receiving pay? (Yes/No)
Has Borrower Name experienced a reduction in hours/income? (Yes/No)
Hire Date:
Borrower Name current job title:
The Name, Title, and phone number (ext. if applicable) of the employer
Buyers guidelines
https://files.consumerfinance.gov/f/documents/cfpb_buying-a-house_mortgage-closing_checklist.p
df
Timing of Documents and Disclosures
TILA RESPA Integrated Disclosure timeline
Initial and Revised Disclosures
A REeBroker Group loan file should be created when a Loan Estimate is generated.
No later than three (3)business days
Loan Estimate is delivered orplaced in the mail after thereceipt of the consumer’sapplication
6 pieces of information neededfor a complete application:
● Name.
● Income.
● Social Security
Number.
● Property Address.
● Estimated Value of
Property.
● Mortgage Loan
Amount
No later than four (4) business
days before closing
Revised Loan Estimate(s) isdelivered or placed in the mail.
Must include reason forchanged or revised LoanEstimate
● If a revised or corrected Loan Estimate(s) is provided to the consumer:
○ Appropriate change circumstances that affect settlement charges;
■ the consumer’s eligibility;
■ credit terms or settlement as requested by the consumer;
■ points or lender credits due to rate lock; or
■ because the initial Loan Estimate expired.
Closing Disclosures
No later than three (3)business days before closing
Closing Disclosure (form H-25
of Appendix H) is delivered or
placed in the mail
If the consumer waived thethree (3) business day waitingperiod:
● a dated writtenstatement describingthe personal financialemergency, modifyingor waiving the waitingperiod, and containingsignatures by allconsumers.
No later than three (3)business days before closing
Revised or corrected Closing
Disclosure is delivered or
placed in the mail.
Correction/revisions due to:
● Inaccurate APR
● A change to the loan
product
● The addition of a
prepayment penalty
If the consumer waived thethree (3) business day waitingperiod:
● a dated writtenstatement describingthe personal financialemergency, modifyingor waiving the waitingperiod, and containingsignatures by allconsumers.
No later than seven (7)business days before closing
Final Loan Estimate isdelivered or placed in the mail
If the consumer waives theseven (7) business day waitingperiod:
● a dated writtenstatement describingthe personal financialemergency, modifyingor waiving the waitingperiod, and containingsignatures of allconsumers.
At or before closing Revised or corrected ClosingDisclosure is provided for anyother changes in loan terms orcosts
Disclosure within thirty (30)days after closing
Revised or corrected Closing
Disclosure is delivered or
placed in the mail
Due to inaccuracy or change inthe amount paid to theconsumer
● Confirm that the creditor does not exceed acceptable tolerance limits for the closing costs
disclosed in the Closing Disclosure.
● Post-closing reviews for accuracy of disclosures and corrective action (if necessary).
Settlement Services
Within three (3) business after receipt ofconsumer’s application
If consumers shop for settlement services,
ensure the consumer is provided a written list
of available settlement service
Within three (3) business after receipt ofconsumer’s application
The consumer is provided the “Your home loantoolkit: A step-by-step guide”Note: If the application was denied before the end ofthe three-day period, providing the booklet is notrequired
Tolerances
Within sixty (60) calendar days after closing The creditor provides refunds to consumer Ifclosing costs exceed acceptable tolerances
Tolerances
These thresholds apply to the fees disclosed on page two of the Loan Estimate under the loan costs
and other costs sections. Loan costs consist of origination fees, fees for required services that cannot
be shopped for, and fees for required services that can be shopped for.
Other costs consist of taxes and other government fees, pre-paid fees, the initial escrow payment at
closing and any other cost the creditor is aware of for services not required by the creditor.
Three Kinds of Tolerances:
1. Zero Tolerances
a. Cannot increase from the Loan Estimate to the Closing Disclosure
b. Fees in the zero tolerance category are so restricted because these are fees for
services the creditor has control over or has access to actual fee amounts.
c. Fees subject to the zero tolerance category include those fees that are paid to the
creditor, the mortgage broker or an affiliate of either party. Common fees in this
category would include any origination fees imposed, fees paid to unaffiliated
service providers for required services that the consumer cannot shop for.
d. One final type of fee subject to zero tolerance is transfer taxes.
2. 10 Percent Cumulative Tolerance
a. All fees that are under this umbrella are added together. As long as the total that is
disclosed on the Loan Estimate does not increase by more than 10 percent from the
total disclosed on the Closing Disclosure
b. Included fees: recording fees and third-party services where the consumer is
permitted to shop for the provider and the consumer picks a provider from your
written list of service providers.
3. No/Unlimited Tolerance
a. All fees in this category can increase by any amount; however, they still must be
disclosed in good faith using the best information available at the time of disclosure.
b. Types of no tolerance fees included: prepaid interest, property insurance premiums
and amounts placed into the initial escrow account, fees for services not required by
the creditor (ie: inspection services).
Compliance with Tolerances
● Zero tolerance items cannot increase at all from the Loan Estimate to the Closing Disclosure.
No tolerance items can increase by any amount as long as disclosed in good faith.
● Zero tolerance: Ensure that providers of services that cannot be shopped for are providing
accurate, reliable fee information. Absent a change in circumstance or another type of
revised Loan Estimate triggering event, increases in that fee will result in a lender credit.
● If the consumer selects a provider from the creditor’s written list of service providers, that
fee remains in the 10 percent cumulative category. If the consumer selects a provider that is
not on the written list, that fee shifts from 10 percent cumulative to no tolerance.
● A revised Loan Estimate under one of the TRID rule triggering events allows the creditor to
reset impacted fees and rely on the revised Loan Estimate for purposes of their good faith
analysis.
● Fee decreases do not impact tolerance rules.
Understanding the TRID rule and fee tolerances - Inman
VA Loan InformationVeteran Affairs (VA) Loan Information
Warnings & Red-Flags for Security Identity Theft
See the warnings and red-flags: here
Working From Home - Guidance
The Department will not take enforcement action against licensees for operating unlicensedbranches to the extent that, during the state of emergency, employees conduct activities from homethat normally would require a branch license, provided that appropriate measures are taken toprotect consumers and their data.
The Department will not criticize student loan servicers or licensees sponsoring mortgage loanoriginators who permit their respective employees to work from home, provided that:
a. The employee does not keep any physical business records at home or anywhere otherthan the licensed location;b. The employee does not meet with any customers at home;c. The licensee has a procedure in place to supervise employees as required by law;d. The employee uses only computers and devices that are encrypted and accesses thelicensee’s network using a virtual private network that is encrypted; and,e. The licensee and employee take all other necessary measures to protect consumer dataprivacy