In the mortgage world when you say the words quality control, post closing quality control loan file reviews immediately come to mind. Did you know that non-originated loan reviews are also considered a part of quality control? Freddie Mac’s Quality Control Best Practices states that as part of your quality control process you should include a random sample of your declined loan applications. In addition, FHA requires that you review a random statistical sample of rejected applications within 90 days from the end of the month in which the decision was made. Regulatory Solutions can assist you with these monthly non-originated reviews to ensure you are in compliance with agency and regulatory requirements including the Equal Credit Opportunity Act (ECOA).
Did you know that your HMDA data plays an important role when you are selling your loans to various agencies?
Most agencies require the lender to submit various HMDA data points as part of the purchasing process. With the new HMDA regulation that just took effect in January 2018, this means that the expanded GMI will play a key role in the purchasing process for most agencies. Freddie Mac in particular specifically requires the lender report the GMI, Rate Spread, and HOEPA information for each loan that Freddie Mac purchases.
Fannie Mae, FHA, and Rural Housing require more than just the reporting of HMDA data points. Before these agencies will consider purchasing loans from your institution, you must show that you have procedures in place and are complying with the current HMDA regulation as part of your Quality Control Program. FHA has an additional requirement that the HMDA information that is being reported be accurate.