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P R E S O R T E D S T A N D A R D

U . S . P O S T A G E P A I D
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1 2 2 0 W A N T A G H A V E N U E
W A N T A G H , N E W Y O R K 1 1 7 9 3
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A Special Look at Community Lending
Getting the Word Out: Leveraging Public Relations
and Social Media to Promote Your Expertise Locally
By Bob Zeitlinger ..................................................................36
Features
The Secret to Better Marketing By Mary Beth Doyle ............4
FHA Insider: Unfair! By Jeff Mifsud ......................................4
CFPB Begins Process of Defining
Larger Participants in Non-Bank Supervision
By Terry W. Clemans ..............................................................8
The NAMB Perspective ..................................................12
Regulatory Compliance Review: The Fannie
and Freddie New Appraisal Portal Uniform
Collateral Data Portal By Jonathan Foxx ............................14
For Managers Only: Do You Have Enough
Time to Manage? By Dave Hershman..................................18
The Elite Performer: Feedback Fuels Your
Business By Andy W. Harris, CRMS ......................................20
NMP Mortgage Professional of the Month:
Raymond Bartreau, Founder/CEO of Best Rate
Referrals and HARPMortgageLeads.com......................22
Tablets: The Future of Mortgage Technology
By Andrew Weiss-Malik ..........................................................24
Lykken on Leadership: Its Time to
Come Together By David Lykken & Jon Traver ......................26
HARP 2.0: Direct Marketing Outlook
By Raymond Bartreau ............................................................28
Dreaming of an LOS By BJ Bounds ....................................31
Loan Servicing: Current and Future Business
Process Assessment By Frank Tibbs ........................................34
Anti-Money Laundering Debuts for Non-Banks
By Jonathan Foxx ................................................................................40
Columns
Heard on the Street ........................................................6
NMP News Flash: March 2012 ......................................16
New to Market ................................................................28
NMP Mortgage Professional Resource Registry ..........44
NMP Calendar of Events ................................................48
Visit Our
ADVERTISERS
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Americas Choice Home Loans .......................... www.achlonline.com ............................................27
Benchmark Mortgage ...................................... www.iambenchmark.info ......................................5
Best Rate Referrals, LLC .................................... www.harpmortgageleads.com ..............................19
Calyx Software ................................................ www.calyxsoftware.com ......................................18
CBC National Bank .......................................... www.cbconnex.com ................................Back Cover
Elliott and Company Appraisers, Inc................... www.appraisalsanywhere.com ..............................12
Equity Loans LLC .............................................. www.equityloans.com ..........................................15
Freedom Mortgage .......................................... www.fmbranch.com ......................Inside Back Cover
Frost Mortgage Lending Group .......................... www.frostmortgage.com/nmp ..............................41
Hometown Lenders .......................................... www.hometownbranch.com ................................21
Icon Residential Lenders, LLC ............................ www.iconwholesale.com ..............................10 & 17
Land Home Financial Services .......................... joinamx@lhfinancial.com ....................................26
Loyalty Express ................................................ www.loyaltyexpress.com ......................................35
Menlo Park Funding ........................................ www.menloparkfunding.com ................................33
Mortgage Brokers Network Corp, Inc. ................ www.mortgagebrokersnetwork.com ......................29
NAMB.............................................................. www.namb.org/legconference ..............................20
NAPMW .......................................................... www.napmw.org ..................................................6
PB Financial Group Corp. .................................. www.pbfinancialgrp.com ......................................10
Polaris Home Funding Corp. (Branches) .............. www.polarishfc.com/TimeForAChange ....................9
Polaris Home Funding Corp. (Wholesale) ............ www.polarishfc.com ............................................25
REMN (Real Estate Mortgage Network)................ www.remnwholesale.com ......................................7
Shortsale Speedway.......................................... www.shortsalespeedway.com/freedemo ................38
Streetlinks LLC ................................................ sales@streetlinks.com ..................Inside Front Cover
TMS Funding.................................................... www.tmsfunding.com ..........................................11
National Mortgage Professional Magazine
TABLE OF CONTENTS
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March 2012 Volume 4, Number 3 Company Web Site Page
A Message From NMP Media Corp.
Executive Vice President Andrew T. Berman
March 2012
Volume 4 Number 3
1220 Wantagh Avenue Wantagh, NY 11793-2202
Phone: (516) 409-5555 / (888) 409-9770
Fax: (516) 409-4600
Web site: NationalMortgageProfessional.com
STAFF
Eric C. Peck
Editor-in-Chief
(516) 409-5555, ext. 312
ericp@nmpmediacorp.com
Andrew T. Berman
Executive Vice President
(516) 409-5555, ext. 333
andrew@nmpmediacorp.com
Joey Arendt
Art Director
joeya@nmpmediacorp.com
Jon Blake
Advertising Coordinator
(516) 409-5555, ext. 301
jonb@nmpmediacorp.com
Beverly Koondel
Marketing Assistant
(516) 409-5555, ext. 316
beverlyk@nmpmediacorp.com
Tara Cook
Billing Coordinator
(516) 409-5555, ext. 324
tarac@nmpmediacorp.com
ADVERTISING
To receive any information regarding advertising rates, deadlines and require-
ments, please contact Senior National Account Executive Karen Krizman at
(516) 409-5555, ext. 326 or e-mail karenk@nmpmediacorp.com.
ARTICLE SUBMISSIONS/PRESS RELEASES
To submit any material, including articles and press releases, please
contact Editor-in-Chief Eric C. Peck at (516) 409-5555, ext. 312 or e-mail
ericp@nmpmediacorp.com. The deadline for submissions is the first of
the month prior to the target issue.
SUBSCRIPTIONS
To receive subscription information, please call (516) 409-5555, ext.
301; e-mail orders@nmpmediacorp.com or visit www.nationalmort-
gageprofessional.com. Any subscription changes may be made to the
attention of Circulation via fax to (516) 409-4600.
Statements, articles and opinions in National Mortgage Professional Magazine
are the responsibility of the authors alone and do not imply the opinion or
endorsement of NMP Media Corp., or the officers or members of National
Association of Mortgage Brokers and its State Affiliates (NAMB), National
Association of Professional Mortgage Women (NAPMW), National Credit
Reporting Association (NCRA) and/or other state mortgage trade associations.
Participation in NAMB, NAPMW, NCRA, and/or other state mortgage
trade associations events, activities and/or publications is available on
a non-discriminatory basis and does not reflect the endorsement of the
product and/or services by NMP Media Corp., NAMB, NAPMW, NCRA,
and other state mortgage trade associations.
National Mortgage Professional Magazine, NAMB, NAPMW, NCRA,
and/or other state mortgage trade associations do not make any misrepre-
sentations or warranties concerning the regulatory and/or compliance
aspects of advertisers, products or services and/or the editorial content con-
tained in NMP Media Corp. publications. National Mortgage Professional
Magazine and NMP Media Corp. reserve the right to edit, reject and/or post-
pone the publication of any articles, information or data.
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Who are the people in your neighborhood?
Are you the face and voice of your local mortgage market? Are you the go-to guy in
your local community when it comes to all things related to the mortgage industry?
If not, you should be, and this month we take a look at various methods as to how
you can become that name and face synonymous with mortgage financing in your
surrounding area. Our focus on community lending is highlighted by a piece from
Bon Zeitlinger of B to Z Communications on page 36, highlighting various methods
to utilize social media and the local media to your advantage. After a read of Bobs
article, you will have the tools necessary to become a key source for local reporters
on real estate- and industry-related issues, and a pro on how to leverage your expertise in the world of
social media.
D.C. here come the mortgage pros!
The National Association of Mortgage Brokers 2012 Annual Legislative & Regulatory Conference in
Washington, D.C. is upon us. From March 18-20, mortgage professionals will have the opportunity to meet
with their elected officials to discuss a number of industry-pertinent topics. In addition to actually visiting
with your senators and representatives, NAMB has assembled a day of education on the legislative process
on Monday, March 19. Among those on hand will be Bart Shapiro, former director of the U.S. Department
of Housing & Urban Developments (HUD) mortgage settlement office and current senior advisor for the
Office of Community Banks and Credit Unions for the Consumer Financial Protection Bureau (CFPB), as the
luncheon keynote speaker. Also from the CFPB, Allison Brown, program manager of mortgage supervision
for the Office of Non-Bank Supervision, will be on hand to discuss loan originator examination guidelines.
Attendees will also get a rare opportunity to take part in a panel discussion on the future of the hous-
ing market, focusing on QM, the three percent rule and the QRM issue. NAMB Government Affairs
Committee Chair John Hudson will moderate the panel featuring Ken Trepreta Esq., director of real estate
services for the National Association of Realtors (NAR); Ken Markison, associate vice president and regula-
tory counsel for the Mortgage Bankers Association (MBA); and Jim Tobin, senior vice president for govern-
ment affairs and chief lobbyist for the National Association of Home Builders (NAHB).
Closing out the event is a chance to network and engage even further with some key Congressional mem-
bers as Rep. Gary Miller (R-CA), Rep. Spencer Bachus (R-AL), Rep. Mary Landrieu (D-LA) and Rep. Maxine
Waters (D-CA) are among the invited guests at a closing reception to round out the event. For more infor-
mation on the Legislative & Regulatory Conference, see pages 12-13 of this issue or visit
NAMB.org/LegConference.
And were not done yet
This issue continues with its regulatory- and compliance-heavy focus as Jonathan Foxx provides us with two
separate pieces this month, one on page 14 looking at the new Uniform Collateral Data Portal (UCDP) used
by the government-sponsored enterprises (GSEs) and on page 40, Jonathan gives a very detailed synopsis of
the new anti-money laundering program for non-bank mortgage lenders and originators. On page 8, Terry
W. Clemans discusses the CFPB and their process of defining larger bank participants in the financial serv-
ices marketplace, and on page 28, Raymond Bartreau provides tips on how to capture your market share
of those eligible for the HARP 2.0 program.
And speaking of Mr. Bartreau
Our March 2012 Mortgage Professional of the Month on page 22 happens to be the aforementioned
Raymond Bartreau, founder and CEO of Best Rate Referrals and HARPMortgageLeads.com. We learn how
Ray got his start in a call center for Direct TV and took his knowledge to grow his direct marketing firm to
become a two-time member of the Inc. 500 list by keeping the client in the spotlight.
All of that and much more can be found in this issue of National Mortgage Professional Magazine, so sit
back and enjoy the ride!
Until next month ...
Andrew T. Berman, Executive Vice President
NMP Media Corp.
National Mortgage Professional Magazine
is published monthly by NMP Media Corp.
Copyright 2012 NMP Media Corp.
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The Association of
Mortgage Professionals
2701 West 15th Street, Suite 536 O Plano, TX 75075
Phone #: (703) 342-5900 O Fax #: (530) 484-2906
Web site: www.namb.org
PresidentDonald J. Frommeyer, CRMS
Amtrust Mortgage Funding Inc.
200 Medical Drive, Suite D
Carmel, IN 46032
(317) 575-4355 O dfrommeyer@amtrust.net
Vice PresidentDonald Fader, CRMS
SMC Home Finance
P.O. Box 1376
Kinston, NC 28503-1376
(252) 523-5800 O dfader@smchf.com
TreasurerJohn Councilman, CMC, CRMS
AMC Mortgage Corporation
2613 Fallston Road
Fallston, MD 21047
(410) 557-6400 O jlc@amcmortgage.com
SecretaryOlga Kucerak, CRMS
Crown Lending
222 East Houston, Suite 1600
San Antonio, TX 78205
(210) 828-3384 O olga@crownlending.com
Past PresidentJim Pair, CMC
Mortgage Associates Corpus Christi
6262 Weber Road, Suite 208
Corpus Christi, TX 78413
(361) 853-9987 O jlpair@aol.com
Rocke Andrews, CMC, CRMS
Lending Arizona LLC
1996 North Kolb
Tucson, AZ 85715
(520) 886-7283 O randrews@lendingarizona.net
Fred Arnold, CMC
American Family Funding
24961 The Old Road, Suite 101
Stevenson Ranch, CA 91381
(661) 284-1150 O fred@fredarnold.com
Kay A. Cleland, CMC, CRMS
KC Mortgage LLC
200 South Wilcox Street #224
Castle Rock, CO 80104
(720) 810-4917 O kaycleland@comcast.net
Deb Killian, CRMS
GMAC
246 Federal Road, Unit C-24
Brookfield, CT 06804
(203) 778-9999, ext. 103 O debkillian@snet.net
Linda McCoy
Mortgage Team 1 Inc.
6336 Picadilly Square Drive
Mobile, AL 36609
(251) 610-0494 O linda@mortgageteam1.com
Donald J. Unger
President
(303) 670-7993, ext. 222
don@advcredit.com
Daphne Large
Vice President & Treasurer
(901) 259-5105
daphnel@datafacts.com
Tom Conwell
Ex-Officio & Legislative
Chair
(800) 445-4922, ext. 1010
tconwell@credittechnologies.com
Nancy Fedich
DirectorConference Chair
(908) 813-8555, ext. 3010
nancy@cisinfo.net
Judy Ryan
Director-Strategic Alliance
Chair
(800) 929-3400, ext. 201
jryan@Kroll.com
Susan Cataldo
DirectorEducation
& Compliance Chair
(404) 303-8656, ext. 204
susancds@cdsusa.net
William Bower
DirectorTenant Screening
Chair
(800) 288-4757
wbower@confinfo.com
Mike Brown
DirectorTechnology Chair
(800) 925-6691, ext. 4350
mike.brown@ncogroup.com
Maureen Devine
DirectorEducation
& Compliance Co-Chair
(413) 736-4511
mdevine@strategicinfo.com
Renee Erickson
DirectorNew Membership
& Elections Chair
(800) 311-1585, ext. 2101
renee@zipreports.com
Terry Clemans
Executive Director
(630) 539-1525
tclemans@ncrainc.org
Jan Gerber
Office Manager/Membership
Services
(630) 539-1525
jgerber@ncrainc.org
President
Laurie Abshier, GML, CME, CMI
(661) 283-1262
lauriea@gemcorp.com
President-Elect
Candace Smith, CME
(512) 329-9040
csmith@wrstarkey.com
Senior Vice President
Jill Kinsman
(206) 344-7827
jill.kinsman@usbank.com
Vice President-Northwestern Region
Nita Cook, GML, CME, CMI
(360) 705-5053
nita.cook@legacyg.com
Vice President-Western Region
Lyman King III, CME, CMI
(916) 967-4653
lking@gemcorp.com
Vice President-Central Region
Lisa Puckett, CME
(405) 741-5485
lpuckett@ameagletitle.com
Vice President-Eastern Region
Christine Pollard
(607) 656-5005
cpollard1046@gmail.com
Secretary
Katheryn M. Farrell
(509) 528-0349
katherynfarrell@yahoo.com
Treasurer
Jeanne Evans, CME
(918) 431-0155
drmjevans@att.net
Parliamentarian
Hulene Bridgman-Works
(800) 827-3034
hulene137@yahoo.com
NAMB Board of Directors
National Association of Professional
Mortgage Women
P.O. Box 451718 O Garland, TX 75042
Phone #: (800) 827-3034 O Fax #: (469) 524-5121
Web site: www.napmw.org
OFFICERS
DIRECTORS
2012 Board of Directors & Staff
National Credit Reporting Association Inc.
125 East Lake Street, Suite 200 O Bloomingdale, IL 60108
Phone #: (630) 539-1525 O Fax #: (630) 539-1526
Web site: www.ncrainc.org
National Board of Directors 2011-2012
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The Secret To
Better Marketing
by Mary Beth Doyle, Founder
Aristotle once said, We are what we repeatedly do.
Excellence, therefore, is not an act but a habit. This is
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loan production. But with a busy spring ahead, you may not
have enough time to stay in touch with clients, partners &
prospects in a meaningful way. Fortunately, theres a simple
methodology that can save time and money.
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t Our wide selection of targeted programs consistently
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able to engage & energize a broader audience than
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t Our proprietary technology automates high-impact
communications that motivate recipients to take action.
Intelligent data mining quickly identifes and promotes
new opportunities. By reaching contacts at the right
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t Our solutions are easy to use. With a few clicks
of the mouse, you can send targeted marketing
campaigns that achieve exceptional ROI. Our
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answer questions and help you make the most of
these powerful resources.
Simply put, LoyaltyExpress can help you maximize closed
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call 877.938.1175
or visit
www.loyaltyexpress.com.
Unfair!
FHA Reserves Fall and New Borrowers Are
Forced to Bear the Burden of Recovery
W
hile the mass media and the general public seem to focus on the
fact that the reserves of the Federal Housing Administration (FHA)
may fall below the mandated amount in 2013 (due to FHA loans
defaulting), I have yet to hear a voice that speaks for the new FHA borrow-
ersthe innocent homebuyers who will be the ones forced to pay for it!
New borrowers monthly housing expense will increase due to another
expected increase in FHA mortgage insurance (MI) premiums!
You will notice that in this article, I will be departing from my usual more mat-
ter of fact style, and you will also notice a thread of sarcasm because I cannot
believe the FHA does not see how their changes will negatively impact the exact
people they were established to help: The hard-working American wage earner.
For any officials of the U.S. Department of Housing & Urban Development (HUD)
that may be reading this please forgive me for pointing out the incongruity, but we
have to get the focus back on the low- to middle-income American workers.
Read on
The HUD budget for fiscal year 2013 states that:
This Budget includes the recently enacted increases in FHA premium levels (April
2011). These increases (in premiums) will boost FHAs capital reservesto better
protect taxpayers against the risk of credit losses by the program and, as a result,
increase federal revenues.
In a Feb. 13 issue of Bloomberg Businessweek appears an article wherein act-
ing Housing Commissioner Carol Galante is quoted regarding the FHAs loan
guarantee request from the treasury. She justifies the premium increase, in order
to keep up the FHA reserves, saying:
Its (the mortgage insurance premiums) more than enough to compensate for the
negative estimate for the draw on Treasury. The Agency also plans to announce
another premium increase in the coming days.
Lets follow the logic (a term I use very loosely here) of the government in this
regard:
With the great losses we have incurred because of the high rate of foreclosures due
to people not being able to afford their payments, we are going to recover our loss-
es by increasing new borrowers house payments by raising the mortgage insurance
premiums.
Lets see if weve got this right ... people cannot afford their mortgages and
hence are foreclosing. As a result, the FHA reserves have plummeted. So FHA will
hike their premiums to make it even more difficult for people to afford their pay-
ments! Brilliant!
Here are some more direct quotes from the 2013 HUD budget:
Giving Hard-Working, Responsible Americans a Fair Shot ...
There is more work to do to ensure that more Americans have the opportunity to
enter the middle class, and that the economic security of middle-class Americans
does not continue to erode.
That brilliant government logic at work once again: We need to help more
Americans enter the middle class, and keep the existing middle class from fur-
ther erosion. Thus, well increase the house payments through MI premiums,
continued on page 14
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Success Relationship Dynamic Excellence
Positive
Attitude
www.IamBenchmark.info | 800-236-1824
Andrew Paul
California Branch Partner
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MetLifes Warehouse
Business Acquired by
EverBank
EverBank has agreed to acquire MetLife
Banks Warehouse Finance business.
Financial terms of the transaction were
not disclosed. The acquisition, which is
expected to close in the first half of
2012, will leverage EverBanks residen-
tial lending expertise and increase
EverBanks assets by approximately
$400 million. The acquisition has been
approved by both parties boards of
directors and remains subject to regu-
latory approvals.
Weve been interested in entering
the warehouse lending business for
some time, said Rob Clements, chair-
man and chief executive officer of
EverBank. The MetLife Warehouse
Finance business represents a natural
business line expansion for EverBank
and diversifies our lending platform
with high quality asset generation
capabilities.
Total Mortgage Services
Now Licensed in Arkansas
Total Mortgage Services LLC has
announced that it has received its
Arkansas Combination Mortgage
Banker-Broker-Servicer License from
the Arkansas Securities Department
and is now able to originate and service
residential mortgage loans in the state
of Arkansas. Total Mortgage is licensed
as a mortgage banker, broker and ser-
vicer in Arkansas and holds License
Number 103968.
Signs of stabilization in the housing
market are beginning to appear and
with rates near record lows it is an
opportune time for borrowers to move
forward and consider purchasing or
refinancing a home, said John Walsh,
president of Total Mortgage. All of our
fully licensed loan officers are very
excited to help responsible borrowers
throughout the state of Arkansas find
the right fixed-rate or adjustable-rate
mortgages to meet their financing
needs.
Total Mortgage is now licensed in 26
states, including: Arkansas, California,
Colorado, Connecticut, Delaware,
Florida, Georgia, Illinois, Massachusetts,
Maryland, Maine, Michigan, Mississippi,
New Jersey, New York, New Hampshire,
North Carolina, Ohio, Pennsylvania,
Rhode Island, South Carolina,
Tennessee, Texas, Vermont and
Virginia, West Virginia and the District
of Columbia, and has four additional
state licenses pending.
Byte Software and
BuildFax Announce
Building Permit Data
Collaboration
Byte Software and Build-
Fax have announced a
partnership to provide
building permit data to
mortgage professionals, allowing
mortgage industry professionals the
ability to quickly verify property
improvements through an interface
between Byte Softwares loan origina-
tion system (LOS) and BuildFaxs
national building permit database.
The integration to Byte Software
allows lenders to access BuildFaxs
property intelligence, which delivers
the additional layer of documentation
needed to enhance loan quality,
reduce transactional risk, and approve
loans with greater confidence. Byte
Softwares LOS offers time-saving
automation of these due diligence
efforts.
BuildFax provides insight into
pending and completed property
improvements and condition not
found in tax assessor data. This infor-
mation can be highly beneficial to
lenders as they work to validate loan
value. More than 400 lenders already
use BuildFax data in their loan
approval and quality control (QC)
processes. The government-sponsored
enterprises (GSEs) acknowledge permit
data as a trusted source for independ-
ent, third-party verification of proper-
ty improvements and condition. In
addition, the access Byte Software
provides to the BuildFax database
enables lenders to easily comply with
emerging Uniform Appraisal Dataset
(UAD) requirements.
We are pleased to partner with
BuildFax to offer our clients access to
this incredibly rich dataset, said Joe
Herb, general manager of Byte
Software. The interface will help
lenders complete these essential vali-
dations quickly, enhancing underwrit-
ing and improving their customers
experience.
N
M
L
S
National Education
National Training
National Networking
NAPMW is a community of nearly 2,000 professionals across the
Country who engage in the mortgage / banking industry. Men
and women from all backgrounds have joined NAPMW because
they want to excel at what they do. Employers who want excel-
lence from their employees engage with NAPMW for up-to-date
education. Both professionals and employers have found there is
a place for them in NAPMW.
To Join NAPMW visit:
www.napmw.org
or call: 1-800-827-3034
Have Questions? Please
feel free to e-mail us at:
napmw1@aol.com
Organized for the purpose of providing education to profession-
als in all phases of the mortgage industry, NAPMW ofers educa-
tion via many venues seminars and workshops held around the
country, on-line, and at its National Education Conference held
each May.
NAPMW membership gives you exclusive access to timely educa-
tion regarding the regulations afecting your career such as a
FREE TO MEMBERS monthly webinar on industry updates AND
our 8 hour NMLS continuing education class ofering (NMLS
Provider # 1400309)
If you believe in helping to elevate the educational standards of
this industry, or assisting in developing the most competent
industry work force, then you believe in NAPMW.
NAPMW is not a womens organization. But since women make
up the majority of professionals in the mortgage/banking profes-
sion, our purpose is to help them advance in business, personal,
and leadership development.
Coast to Coast Associations
Discounted Services
Industry Updates
Education
Networking
Leadership
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GSF Mortgage Announces
CRM Partnership with
ARG Interactive
GSF Mortgage has
announced that it has
formed a partnership
with ARG Interactive, a
marketing technology company offering
automation and interactive Web site solu-
tions to mortgage companies, banks and
credit unions.
We are consistently looking for ways to
engage and get closer to our customers,
said GSF Mortgage Chief Operating Officer
Chad Jampedro. And we are extremely
pleased to develop this business relation-
ship with ARG Interactive as part of this con-
certed effort.
Jampedro said ARGs proprietary cus-
tomer retention management (CRM) system,
marketing automation and lead generation
technologies are the best in acquiring new
customers and retaining existing customers.
ARGs customized solutions suit our
needs specifically for the mortgage
industry, said Jampedro. Having a
solution to parallel our needs is just
what we were looking for.
DocuSign and Cartavi
Agreement to Streamline
Cloud-Based Doc
Management
DocuSign has
announced that
Cartavi, the simple document sharing
continued on page 10
AHMSIs Expansion and
Focus on Residential
Prompts Name Change
American Home
Mortgage Servicing
Inc. (AHMSI) has
announced that the company will
change its name to Homeward
Residential to reflect its expansion into
residential lending and other real
estate finance-related businesses. The
full transition to the new name,
Homeward Residential, is expected to
be completed in the second quarter of
2012. AHMSIs portfolio of services was
expanded in October 2011 with the
opening of the companys correspon-
dent and warehouse lending opera-
tions. During the past 12 months,
AHMSI has added new businesses to
support the needs of customers in a
challenging marketplace, including
loan closing services, real estate-owned
(REO) management, home valuation,
special servicing, sub-servicing and
asset management consulting.
This announcement is not simply a
name change. Over the past 12 months
we have built a full-service mortgage
banking enterprise with a broad spec-
trum of offerings and expertise in lend-
ing, servicing and a variety of related
services, said Dave Applegate, presi-
dent and chief executive officer of
AHMSI.
The name Homeward Residential
evolved after employee and customer
input, followed by additional research,
analysis and audience testing.
We believe that homeownership
remains a significant part of the
American dream, and Homeward is
the ideal identity to support the aspira-
tions of our customers, said Applegate.
Our exceptional and talented employ-
ees played significant roles in helping
us rename our company, and their
input was valued among the entire
organization. Homewards ultimate
success rests on those same employees
who are passionate about the work they
do and remain steadfastly committed
to finding the best possible solutions
for homeowners.
AHMSI is currently ranked as the
13th largest mortgage servicer in the
country, managing nearly $71 billion in
loan servicing, representing approxi-
mately 374,000 customers. Since its
inception in April 2008, AHMSI has
modified over 195,000 mortgage loans,
including over 32,000 under the U.S.
governments Making Home Affordable
Program. AHMSIs more than 3,000
associates work each day with the mis-
sion of helping families preserve their
dream of homeownership.
Stewart Title and Calyx
Partner on Order Speed
and Efficiency
Stewart Title has
announced the
integration of its online ordering plat-
form, Orders Gateway, powered by
PropertyInfo Corporation, a Stewart
company, into Calyx Point, a leading
mortgage origination provider. The
integration of the two systems enables
Point users to quickly and securely
place and track orders with Stewart
Title from within Calyx Point, simplify-
ing the ordering process and enhanc-
ing the customer experience. Orders
Gateway offers 24/7 availability, elim-
inates the need to re-enter informa-
tion and provides a convenient office
selection.
Both Stewart and Calyx Software are
committed to streamlining and opti-
mizing the loan origination process for
our lender customers, said Glenn
Clements, group president, direct oper-
ations for Stewart Title Company. Now,
with this integration, it is easier than
ever for Calyx Point users to place title
orders with Stewart Title.
8
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CFPB Begins Process of Defining
Larger Participants
in Non-Bank Supervision
By Terry W. Clemans
On Feb. 17, 2012, the
Consumer Financial
Protection Bureau
(CFPB) issued its first
proposed rule specifi-
cally defining who falls into the larger
participant category in the non-bank
financial services markets for future
regulation. The first industries of focus
for the CFPB are consumer (credit)
reporting and debt collection. This pro-
posed rule-making is required by
Section 1024 of the Dodd-Frank
Financial Reform Act of 2010.
The CFPBs announcement in the
Federal Register states:
This proposal is the first in what the
Bureau intends to be a series of rules to
define larger participants in specific mar-
kets for purposes of establishing, in part,
the scope of coverage of the Bureaus non-
bank supervision program.
In the proposed rule, the CFPB sug-
gests establishing a test for each market
to determine whether a non-bank entity
is a larger participant of that market. For
the consumer credit reporting and debt
collection markets, the Bureau is propos-
ing a test that measures the annual
receipts of the firm for potential inclu-
sion into the larger participant catego-
ry. The definition of annual receipts was
adapted from the definition of the
term used by the Small Business
Administration (SBA) for purposes of
defining small business concerns. The
proposed threshold for the consumer
debt collection market is more than $10
million in annual receipts and, for the
consumer reporting market, is more than
$7 million in annual receipts.
Though looking to the SBA for a uni-
versal financial designation to create the
larger participant category provides a
quick and easy divider to monitor, it may
create difficulties in its application. The
consumer credit reporting industry has
already been segregated into larger par-
ticipants by its primary federal law, the
Fair Credit Reporting Act (FCRA). FCRA has
split the industry into two basic segments
based on primary business models and
assigned some specific regulations for
each model.
The national credit bureaus or repos-
itories are defined in FCRA Section
603(p):
Consumer Reporting Agencies (CRA) whose
manner of business includes assembling or
evaluating, and maintaining for the purpose
of furnishing consumer reports to third par-
ties, both (1) [p]ublic record information
(and) (2)[c]redit account information from
persons who furnish that information regu-
larly and in the ordinary course of business.
FCRA Section 607(e), provides for credit
reporting agencies that are known as
resellers (who are the producers of all mort-
gage reports), and defines resellers as those
who procure a consumer report for purpos-
es of reselling the report
Despite the fact that the same laws
cover both the Repository CRA and
Reseller CRA, the business models are
very different and proper regulations
and auditing for them would need to
have much different focuses to assure
each business model is compliant. For
example, the repository CRA batch
processes tens of millions of pieces of
information into its database from
creditors on every consumer in the
country with a credit file, on a daily
basis. Resellers, on the other hand, indi-
vidually process information a single
piece at a time, after the accuracy or
completeness of that particular report
has been questioned. Further, the
reports in the resellers databases are
only on the consumers for whom they
have had a report requested, and that
report is for that specific transaction
only.
In addition to the difference in busi-
ness models, there is another major dif-
ference in these two entities that directly
ties to the CFPBs desire to define the
industry by revenue. Each of the three
national repositories has annual revenue
in the billions. All resellers, even the very
largest in the industry, have annual
receipts in the millions. The smallest
repository is at least 10 times larger than
the largest reseller.
In whatever manner the CFPB deter-
mines who is a large participant, they
are authorized to supervise these larger
non-bank entities by requiring them to
submit reports and undergo examina-
tions to:
(1) Assess compliance with Federal con-
sumer financial law; (2) obtain informa-
tion about such persons activities and
compliance systems or procedures; and (3)
detect and assess risks to consumers and to
the consumer financial markets.
This proposed rule only pertains to
defining how to determine the larger par-
ticipants in certain markets for purposes
of the CFPBs non-bank supervision
authority and does not impose any new
substantive consumer protection require-
ments. The announcement also serves as
a reminder that all non-bank entities,
regardless of size, are subject to the CFPB
regulatory and enforcement authority for
compliance with any applicable federal
consumer financial law, and that the
CFPB is planning on being an active regu-
lator over the industries in its jurisdiction.
For more information, or to provide
the CFPB with a comment (comments
are due by Tuesday, April 17) on this
proposed rule, log on to
https://www.federalregister.gov/arti-
cles/2012/02/17/2012-3775/defining-
l ar ger - par t i c i pant s - i n- c er t ai n-
consumer- fi nanci al - product- and-
service-markets.
Terry W. Clemans is executive director
of the National Credit Reporting
Association Inc. (NCRA). He may be
reached at (630) 539-1525 or e-mail tcle-
mans@ncrainc.org.
First up
credit reporting
and collection
agencies
all non-bank entities, regardless of size, are subject to the
CFPB regulatory and enforcement authority for compliance with
any applicable Federal consumer financial law
9
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Change to...
Ability to bank your loans in house or broker them
#1 USDA Rural Development lender in multiple states
Nationally recognized for our quality in FHA/VA lending
World-class, back-room service with direct access to your underwriter
Keeping your professional identity by using a DBA (subject to state rules)
Branching for grown-ups
If you are a seasoned professional ready for a change and desire
more information, call us at 616-667-9000, or send an e-mail to:
TimeForaChange@PolarisHFC.com
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10
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heard on the street continued from page 7
platform for real estate, has integrated
with DocuSign to help real estate pro-
fessionals close more deals faster in
the cloud. Were very excited to pro-
vide Cartavi subscribers the opportuni-
ty to close real estate transactions
completely in the cloud as a result of
our integration with DocuSigns
eSignature solution, said Glenn
Shimkus, co-founder and chief execu-
tive officer of Cartavi. Our users asked
for this and were proud to now give
them fast and easy access to DocuSign,
the real estate industry standard for
electronic signature.
Cartavis cloud-based solution lets
real estate professionals and those
related to a transaction securely man-
age and share documents with every-
one involvedfrom any computer,
iPad, iPhone or Android device.
DocuSign is now available from within
Cartavis user-friendly document man-
agement platform, allowing Cartavi
users to send real estate documents for
signature with a single click. Integrated
with DocuSign, Cartavi expedites real
estate transactions from start to fin-
ishso all parties involved can keep
the transaction moving to close faster.
Cartavi provides real estate agents
and brokers with state-of-the-art tech-
nology to better manage the end-to-end
process, said Tom Gonser, founder and
chief strategy officer at DocuSign.
Cartavi will help real estate profession-
als leverage the power of the DocuSign
Global Network to streamline real
estate transactions and create a better
experience for their clients.
Current DocuSign customers need
only enter their DocuSign credentials
the first time to begin using DocuSign
directly within Cartavi. No additional
setup is required.
LendingQB and FirstClose
Title Announce GFE
Quoting Partnership
LendingQB and FirstClose
Title have announced a
partnership that com-
bines instant cash to
close quotes with real-
time automated under-
writing and loan pricing all within a unified
loan origination platform. The integration
enables mortgage lenders to reduce closing
costs for borrowers and simultaneously
populate guaranteed GFE data within the
LendingQB loan origination system (LOS).
We actively seek out best pricing
among major underwriters to deliver
pure, unaltered comparative rate
quotes, said Cynthia Waterman, presi-
dent and chief executive officer of
FirstClose Title. This allows us to present
quotes which average $500 to $1,000
below competing GFE quotes, providing
lenders with a cash to close advantage
that makes their offer more competitive
and secures a relationship with a poten-
tial borrower more quickly.
The integration between LendingQB
and FirstClose Title makes it easy for
lenders to generate a Good Faith
Estimate (GFE) quote directly within the
LendingQB loan origination system.
Lenders can quickly retrieve quotes for
title insurance, settlement charges,
recording charges, and transfer taxes
and automatically populate the data to
the GFE on their loan file. Lenders can
save between 15 and 30 min. per loan
file using the integration. But more
importantly, FirstClose Title guarantees
the accuracy of the GFE data, which
protects lenders from having to cover
costs due to poor GFE data entry.
As a loan origination system, our
goals are to increase a lenders efficien-
cy and maintain data integrity, said
Binh Dang, LendingQBs managing
partner. The integration with
FirstClose actually goes beyond these
goals and has a direct impact on a
lenders ability to drive revenue. It
makes lenders more competitive by
improving point of sale pricing and
increasing consumer selection. When
you combine FirstClose Titles best-exe-
cution rate quotes with our automated
underwriting and loan pricing technol-
ogy all wrapped up in a web-based loan
origination system, youve got a top-
line technology platform that will have
an immediate impact on a lenders bot-
tom line.
Loan Resolution
Corporation Announces
Acquisition of KeyLink
Asset Management
LRC Asset Manage-
ment, a majority-
owned company of
Loan Resolution Corporation, has
announced the acquisition of KeyLink
Asset Management. KeyLink will now be
known as LRC Asset Management.
Originally founded by Damien Chiodo
and Ty Reed, KeyLink has been known
for their unique real estate-owned
(REO) management model.
KeyLink has been doing some very
innovative things in REO asset manage-
ment that caught our eye. We have
always said that we wouldnt get into
any line of business unless we felt we
could do it better than the next compa-
ny, and KeyLink was doing it better
than the next company, said Travis
Hamel Olsen, chief operating officer of
Loan Resolution Corporation.
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model to LRCs broad base of contacts
said Reed, formerly of KeyLink and now
managing partner of LRC Asset
Management. The model produces the
execution and performance that indus-
try leaders are so desperately searching
for today.
WFG National Title and
ClosingCorp Partner on
Title Insurance Initiative
ClosingCorp has announced that WFG
National Title Insurance will provide its
independent title agents access to
ClosingCorps suite of products for the
delivery of title insurance rates. WFGs
rates will be included in ClosingCorps
SmartGFE service to deliver timely, up-
to-date rates directly to lenders for
good faith estimates (GFEs) that they
provide to mortgage loan applicants.
WFG will recommend that its inde-
pendent title agents post
ClosingCorps SmartGFE Calculator on
their Web sites to instantly quote title
insurance rates to their real estate
agent and lender clients at any time.
Additionally, WFGs title insurance
rates will be available to consumers
through ClosingCorps Closing.com,
enabling individuals to shop for resi-
dential closing services and rates.
When the new GFE/HUD-1 makes its
way into our industry, as we believe it
will, later this year, the SmartGFE will
be a real boon to agents. WFG National
Title and ClosingCorp are offering our
agents access to a powerful and flexible
tool allowing their lender customers to
accurately complete the GFE based on
the new rules, with the agents fees and
title premiums pre-loaded, said Joseph
Drum Esq., executive vice president for
WFG National Title Insurance Company.
WFG National Titles independent title
agents will now receive discounts on the
SmartGFE Calculator, which instantly gen-
erates title and settlement rates, as well
as transfer tax and recording fees.
WFG is dedicated to supporting its
independent title agents and providing
them with the tools they need to both
adapt and succeed in a changing market-
place, which aligns with our goal of pro-
viding the most accurate data to clients in
the fastest method possible, said Paul
Mass, president of ClosingCorp. Our
nationwide network of more than 10,000
real estate service providers allows us to
deliver the most extensive, current rates
and fees available to all parties involved
in the real estate transaction. The combi-
nation of our data and technologies will
enable WFG to better serve agents,
lenders and consumers.
Integra Group Real
Estate Launches
Short Sale Division
Integra Group
Real Estate LLC,
a brokerage firm
specializing in the marketing and sale
of real estate-owned (REO), U.S.
Department of Housing & Urban
Development (HUD) and distressed
properties, has officially introduced
its short sale department to assist
homeowners with the resale of
homes nearing foreclosure. The
department will led by Ofelia
Lichtenheld, designated broker for
Integra, and provides the specialized
expertise and skill sets that are need-
ed in order to more successfully
process a short sale transaction.
The short sale department enables
homeowners to sell the property with
the appropriate valuation in the short-
est time and avoid the ramifications of
having a foreclosure on their credit his-
tory, said Eric Lichtenheld, president of
Integra Group.
Mortgage Professionals
to Watch
I Real Estate Mortgage Network Inc.
(REMN) has named Kathryn Paige as
mortgage loan originator for special
projects.
I Barry Habib has joined Residential
Finance Corporation (RFC) as chief
marketing strategist.
I Brooks Bosley, current president of the
Maryland Association of Mortgage
Professionals (MAMP), has been named
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T
ime is a meas-
urement and let
me tell you, the
months just seem to
be flying by. It has
been an amazing win-
ter and it seems like
just yesterday we were
talking about NAMB/WEST. I dont know
about you guys, but my office has seen
business really pick up and we are start-
ing to see more purchases than refi-
nances. However, more than ever, the
FHA Streamlines seem to be coming out
of the woodwork. I wish we could refi-
nance them with their old mortgage
Insurance (MI) because they would be
saving a lot of money then.
It looks like the Secretary of the U.S.
Department of Housing & Urban
Development (HUD) is looking into
Streamlines using a different method on
the MI. At the time this article went to
press, nothing has happened, but we
should look for something by the middle
to the end of March. Keep calling your
past customers and get them ready.
By the time that you read this, we will
have had two of our leaders involved in
the Small Business Panels for the
Consumer Financial Protection Bureau
(CFPB). I hope to update all of you at
about these panels on March 18-20 at the
2012 NAMB Legislative & Regulatory
Conference in Washington, D.C. We have
a great program scheduled there and
some interesting guests. This is, by far,
the best get together that we have and to
be able to take our voice up to the Hill
and let your legislators know what is
going on is fantastic. Some of the speak-
ers are going to make attending this con-
ference worth the price.
Our membership continues to grow,
but not at the rate that it should. I find
that many members are joining, but are
not asking their fellow brokers to join. It is
a proven fact that those who join their
association become better at what they do
and how they do it. It must be because
they are better informed and understand
that this professional organization that
they belong to makes them better at what
they do, day in and day out, as a mortgage
professional. I personally tell every cus-
tomer that I belong to NAMB, and I have a
designation, the Certified Residential
Mortgage Specialist (CRMS), and I use that
as a reason of why I am better qualified
than the banks mortgage originator. I also
display the NAMB logo on my desk. I feel
that it sets me apart from the competition,
especially when they ask me about what I
had to do to be in this business. So brag
about yourself a little because you deserve
it. Just make sure that you dont go over-
board. Give your customer the facts on
what you have done to make sure that if
this customer is dealing with you, he
knows why you are a step above.
Are you a person that would like to step
up to the plate and help NAMB? We are
getting ready to start asking members to
nominate other members to be on our
Board of Directors. We are looking for
those who are not only good at what they
do, but want to make a difference. I know
that when I was on my local state associa-
tion Board, I helped out on some NAMB
committees and thought that I can help
make a difference in not only the mort-
gage business, but in the association. One
of the requirements you need is that you
need to be certified with a CRMS or
Certified Mortgage Consultant (CMC) desig-
nation. The by-laws state that only two
members can be on the Board without a
designation, however, to move up into the
Executive Board, you need a professional
designation. So if you do not have one, go
get one. It not only makes you eligible to
serve on the Board, but it also stands you
out in front of mortgage originators who
are not designated.
I know that there are many of you who
are sitting on the sidelines reading this
article and saying, Why do they keep ask-
ing for people to join? Because I have
been in Washington and I have been
asked, How many members do you
have? It is a little embarrassing that we
tell them approximately 5,100 members,
and when they ask, How many origina-
tors are there out there nationwide, I
want to hide. We only have 4.5 percent of
all mortgage originators as members, and
I dont think that it is because of the dues.
Platinum Membership is $120 and Silver
Membership is just $50 annually. I have
been a mortgage broker since 1988 and
there are times that we spent that much at
dinner or a night out on the town. I see
many of my fellow originators out at the
bar, and I know that they spend that much
on drinks and food, so the cost is not the
problem. I know that some of the origina-
tors are making a lot more than what they
made two years ago and they still are not
members. So why is it? What makes these
people just sit around and not join? What
makes them sit by the sidelines and let
other people handle it?
I have spoken with many of you, and
some of you reply, Why should I join, you
are going to represent me anyway! I can
be a member of the SILENT MAJORITY and
I will reap the benefits of what you do!
What would you do if it became mandato-
ry that you join a professional trade asso-
ciation? Realtors now require this. If you
want to use the term REALTOR, you have
to be a member of the National
Association of Realtors (NAR). Any idea
how many members there are in NAR
try 1.2 million! Yes 1.2 million! If you want
to list your houses on the Multiple Listing
Service (MLS), you have to be a member of
that local service. And let me tell you,
almost all of them are members. So, why
arent you a member of NAMB? Maybe
you dont know what the goals are of our
association. Here are just a few for you:
1. Our main goal is to serve our members.
To promote professional growth and
quality of life. To make available pro-
grams and services that makes you a bet-
ter originator or mortgage professional.
2. To improve our profession. Promote
the highest quality education and pro-
fessionalism. Promote competence
and ethical conduct.
3. Provide public understanding of our
profession, the role of the mortgage
professional in the public.
4. To abide by a Code of Ethics and the
Best Practices of our Profession.
5. To keep you up to date with changes
in the Law and Common Practices.
NAMB works directly with our
Government Affairs team to make sure
that you have first-hand knowledge of
new rules and laws that affect you
every day. We provide you with a strat-
egy to make sure that everything you
do every day is compliant with the law.
6. To work with our states to improve
membership and keep them informed.
So again, I ask you, why do you not
belong to NAMB? Now that you have an
understanding of what some of our
goals are, I dont think that you can
truthfully stand by and not join. So take
three min. and log on to JoinNAMB.org
and join today. The person that will get
the most out of this is YOU! You have
nothing to lose and everything to gain!
I look forward to seeing your name
in the New Member section.
Sincerely,
Donald J. Frommeyer, CRMS,
President
NAMBThe Association of Mortgage
Professionals
The Presidents Corner: March 2012
Web: www.appraisalsanywhere.com
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Sunday March 18, 2012
1:00 p.m.-5:00 p.m. ......Registration
5:00 p.m.-7:00 p.m. ......NAMB Board of Directors Meeting
Monday, March 19, 2012
7:00 a.m.-6:00 p.m. ......Registration
7:30 a.m.-8:30 a.m. ......Breakfast
8:30 a.m.-8:45 a.m. ......Opening Remarks From NAMB President Don
Frommeyer & Herman Churchwell of Provident
Funding, NAMB Legislative Conference Sponsor
8:45 a.m.-10:15 a.m.......Opening Session: Working Together for Housing
Panel Discussion The Future of Housing
(QRM, QM, the Three Percent Rule, G-Fees and
Beyond), Moderated by John Hudson
I John Hudson of the National Association of Mortgage Brokers (NAMB)
I Ken Trepreta of the National Association of Realtors (NAR)
I Ken Markinson of the Mortgage Bankers Association (MBA)
I Jim Tobin of the National Association of Home Builders (NAHB)
10:30 a.m.-11:45 a.m.....Helping Todays Homeowners: Refinance Pro-
grams, Presented by Faith Schwartz of HOPE
NOW
Noon-1:30 p.m. ............Luncheon & Keynote Speaker: Bart Shapiro of
the CFPB
2012 NAMB Legislative & Regulatory Conference
Sunday-Tuesday, March 18-20
Capitol Skyline Hotel 10 I Street, Southwest Washington, D.C.
Sponsored by
For more information on the NAMB 2012 Legislative & Regulatory Conference,
visit NAMB.org/LegConference.
Schedule of events
(Subject to change)
1:45 p.m.-2:45 p.m. ......Loan Originator Examination Guidelines,
Presented by Allison Brown of the Consumer
Financial Protection Bureau (CFPB)
3:00 p.m.-4:00 p.m. ......Ten Things You Should Know Before You Get
Examined by the CFPB, Presented by Larry
Platt, a partner with K&L Gates
4:10 p.m.-5:00 p.m. ......Advocacy and Your Lobbying: Tips and Tools
for Effective Advocacy, Presented by NAMB
Lobbyist Roy DeLoach of DC Strategies Group
5:00 p.m.-6:00 p.m. ......NAMB Blog/State Blog, Presented by NAMB
Communications Chair Fred Arnold, CMC
6:30 p.m.-8:30 p.m. ......NAMB 2012 Legislative & Regulatory
Conference Opening Reception
Tuesday March 20
7:00 a.m.-Noon ............Lobby Day Registration
9:30 a.m.-5:30 p.m. ......Lobby Day Hill Visits
5:30 p.m.-8:30 p.m. ......Capitol Visitors Center: Come Meet Key
Congressional Members
I Welcome from NAMB President Don Frommeyer
I California Rep. Gary Miller (confirmed)
I Alabama Rep. Spencer Bachus
I Louisiana Rep. Mary Landrieu
I California Rep. Maxine Waters
9:00 p.m.-11:00 p.m. ....Lobby Day Debriefing
14
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assuring that those hard-working
Americans were claiming to help can-
not buy a home or stay in one. Again,
sheer brilliance.
Now a quote from HUDs Mission
Statement:
HUDs mission is to create strong, sus-
tainable, inclusive communities and
quality affordable homes for all.
And the way they will fulfill that mission
is to make such a reality more impossible by
increasing the cost of being a homeowner
through MI premiums and make homes less
affordable for all FHA homebuyers. But
wait, it gets better: In FHAs move to make
homes affordable, they plan to reduce the
amount a seller can contribute toward
buyer closing costs from six percent to three
percent of the purchase price. I think these
folks left their thinking caps at home.
Another quote from the budget:
The economy lacks a vibrant housing
sectorand a balanced housing poli-
cythat enables families to rent or own
a high-quality, affordable home ...
And from HUDs Mission Statement:
HUD is working to strengthen the hous-
ing market to bolster the economy ...
Here are some historical facts about
MI premiums for the standard 30-year
fixed loan with less than a five percent
downpayment which accounts for near-
ly all of FHAs loans:
I July 2008: Housing and Economic
Recovery Act in 2008, authorizes FHA to
increase Upfront Premiums to three
percent.
I April 2010: Upfront Premium increased
from 1.5 percent to 2.25 percent.
I April 2011: The Annual Premium
increased from 0.90 percent to 1.15
percent.
I October 2010: The Annual Premium
increased from 0.55 percent to 90
percent.
I October 2010: The Upfront Premium
is decreased from 2.25 percent to
one percent.
What we see from these facts are
increases in the Annual Premium of over a
100 percent, which increases a house pay-
ment significantly. In addition, we see a
decrease in the Upfront Premium of over
100 percent, which increases the mortgage
amount because its financed, but only
slightly affects the house payment. What
this means to a homeowner is that with a
$150,000 loan amount the monthly insur-
ance has increased from $69 to $144; a
$75 increase. Now this may not seem like
a lot for a family with a higher net dispos-
able income, but for many families, $75 is
significant, and it also decreases the pur-
chase price they can afford.
Now lets look at these changes from
another perspective and we will see how
many new borrowers are being taxed and
essentially bearing the whole burden of
helping the FHA recover. Prior to the
October premium changes, using rounded
figures, and staying with the $150,000
example, a homebuyer would pay $3,400 in
the Upfront Premium and assuming they
kept that loan for 10 years, another $8,000
for a total of $11,400. With the current pre-
mium amounts, the Upfront Premium
would be $1,500 and 10 years of payments
would be $17,000 for a total of $18,500. So
in this example, the homebuyer today is
paying the FHA $7,000 more than before.
While I understand that FHA is legislat-
ed to be a self-sustaining agency, it seems
grossly unfair to make the new homebuy-
ers bear the burden of the housing crash.
I think it is time for the FHA to look for
new ways to cut costs and streamline
their operational costs in order to get
back to their commitment to helping the
hard-working American in earnest.
Jeff Mifsud is founder of Michigan-based
Mortgage Seminars LLC, a former FHA
underwriter with 15-plus years of experience
originating FHA loans, an FHA expert for
LoanToolbox.com and creator of The FHA
Originator, a monthly FHA newsletter. Jeff
may be reached by phone at (248) 403-8181
or visit www.MortgageSeminars.com.
fha insider continued from page 4
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Regulatory
Compliance
Review
The Fannie and Freddie New Appraisal
Portal Uniform Collateral Data Portal
By Jonathan Foxx
A critical appraisal
requirement deadline
approaches!
1
The requirement
went into effect on Dec.
1, 2011. The deadline is
March 19, 2012.
On and after March 19, 2012, Fannie
Mae and Freddie Mac (GSEs) will mandate
compliance with their new Uniform
Mortgage Data Program (UMDP Program).
2
The UMDP Program has been developed
under the direction of their regulator, the
Federal Housing Finance Agency (FHFA).
The UMDP Program implements uni-
form appraisal and loan delivery data
standards that are meant to support data
accuracy and integration of mortgage
data. Actually, the UMDP Program imple-
ments two of Fannie Maes Loan Quality
Initiative (LQI) objectives: Electronic sub-
mission of appraisal data and collection of
additional loan data in an updated for-
mat. Thus, the UMDP Program is an intrin-
sic part of the LQI requirements.
The UMDP Program includes:
I Uniform Appraisal Dataset (UAD):
Standardizes key appraisal data ele-
ments.
I Uniform Collateral Data Portal (UCDP):
Electronic collection of appraisal data.
I Uniform Loan Delivery Dataset
(ULDD): Leverages MISMO Version
3.0 standard.
3
In this article, I will pay particular
attention to the Uniform Collateral Data
Portal (hereinafter, UCDP Portal).
4
The
UCDP Portal was activated in June 2011.
This is a single portal for submitting
data electronically of an appraisal file.
Lenders must use the UCDP Portal to
those data files, including the Uniform
Appraisal Dataset (UAD),
5
when applica-
ble, before the delivery date of the
mortgage to Fannie Mae and Freddie
Mac.
Appraisal report forms for all conven-
tional mortgages delivered to the GSEs on
or after March 19, 2012 must be transmit-
ted through the UCDP Portal (prior to the
delivery date of the mortgage) under these
two conditions:
I The loan application is dated on or
after Dec. 1, 2011, and
I An appraisal report is required.
Variances and waivers will not be
given to a lender from either GSE for
the subject data, if a lender is not able
to submit an appraisal before a single
delivery or is not ready by the
announced effective dates.
The loans subject appraisal data
upload to the UCDP Portal at this time are
conventional loans sold to Fannie and
Freddie. FHA, VA, and Rural Development
mortgages are excluded from the UCDP
Portal requirement. Mortgage brokers
cannot register for UCDP Portal.
6
There are three user categories that
will access the UCDP Portal:
I Lenders that have an existing Fannie
Mae Seller/Servicer Number
I Correspondents that do not have an
existing Fannie Mae Seller/Servicer
Number
I Agents (Appraisal Management
Companies, Appraiser Vendors)
Overview
There are many moving parts to the
UMDP Program, but we will highlight
the UCDP Portal.
The rule of thumb is, as follows: If an
appraisal is required, the appropriate
appraisal report form should be trans-
mitted via the UCDP Portal for all con-
ventional mortgages with application
received dates on or after Dec. 1, 2011
for loans delivered to the GSEs on or
after March 19, 2012.
Starting the
registration process
It is not possible to submit to the UCDP
Portal unless the lender sets up a primary
lender administrator with Fannie Mae
and/or Freddie Mac. This administrator
must be the same individual for both
Fannie and Freddie. So-called backup
lender administrators are permitted, if the
lender chooses to delegate certain admin-
istrator responsibilities to other lender
employees; however, the initial set-up
must be established by the primary lender
administrator.
There is a rather simple, four step
process to registering for and setting up
the UCDP Portal, consisting of:
7
I Step 1: Registration;
I Step 2: Completing the UCDP Set-up
Form;
continued on page 16
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MARCH 2012
regulatory compliance review continued from page 14
I Step 3: Accessing the UCDP registra-
tion URL; and
I Step 4: Completing UCDP registra-
tion by clicking on the registration
URL (see Step 3).
Fannie Mae and Freddie Mac have
separate registration processes for
UCDP Portal.
Registration with Fannie Mae:
I Fannie Seller/Servicers and Non-
Seller/Servicers.
O Download and review Getting
Registered for UCDP.
O Seller/Services: Use their current
Fannie Mae User ID.
I New users and Non-Seller/Servicers:
receive their User ID in an e-mail
from Fannie Mae.
Registration with Freddie Mac:
I Download and review Getting
Registered for the Uniform Collateral
Data Portal.
O The Freddie Mac UCDP Authoriza-
tion Code is e-mailed from Freddie
Mac.
Accessing the
UCDP Portal
The UCDP Portal is accessed via
eFannieMae.com.
Appraisals must be submitted to the
GSEs prior to the mortgages delivery
date of the mortgage and must include
the applicable required appraisal
report forms for all conventional
appraisal reports.
8
The appraisal data
remains in the UCDP Portal, even if the
loan is not delivered to a specific GSE.
The GSEs have provided several means
by which lenders may access the UCDP
Portal, both through a Web-based URL
and also vendor-based technology. At
this time, the following are the access-
ing methodologies:
I Web-based:
O Accessing the URL allows users to
browse and upload files in XML or
PDFs.
I Vendor-based:
O The GSEs have a published list of
vendors that provide integrated
systems into the UCDP Portal.
9
There are no transaction fees
charged by the GSEs for using the UCDP
Portal, either through the web-based or
the vendor-based methods. However, if
the appraisal requires conversion from
the PDF to the XML format, there is a
per transaction fee charged by Veros
Real Estate Solutions, the technology
provider selected for the UCDP Portal.
10
Using the UCDP Portal
Through the UCDP Portal, the lender
submits the electronic appraisal data
files. A maximum of 10 appraisal data
files are permitted per upload request,
file size permitting.
11
But the data also is
given a status by the GSEs and findings.
These occur due to the fact that the
uploaded appraisal data go through an
internal review, which includes UAD
Compliance Check.
Appraisals that pass are given the
status Successful. A failed review,
dubbed Not Successful, indicates that
the submission is in some way not com-
pliant, perhaps signifying errors that
require an appraisal to be corrected by
the appraiser.
There is a Submission Summary Report
(SSR) for each appraisal upload. The SSR
contains a summary of the appraisal sub-
mission for each loan, the status of the
submission, and an identifier tagged by
the UCDP Portal, termed the Document
File Identifier (or Doc File ID). Each Doc File
ID is assigned per loan and must match
that loans delivery data provided to the
GSEs. The status of Successful must be
output from the UCDP Portal prior to the
loan being delivered to the GSEs.
Appraisals cannot be transferred
within the UCDP Portal from one entity
to another (i.e., from a correspondent
to an aggregator). Therefore, lenders
and their correspondents must develop
a process to ensure that the aggregator
receives the Doc File ID after appraisal
date upload and prior to loan delivery.
An appraisal that receives a Doc File ID
will be accessible for viewing within the
UCDP Portal for up to three years. If the
appraisal is modified after the original
submission date and the submission
needs to be updated, the lender may
replace the original submission or add
another appraisal, if appropriate (i.e.,
such as may occur on appraisals that sup-
port a new construction loan or for new
construction where the original appraisal
is no longer valid because of its age).
It is important, therefore, that the
lender is in a position to review and,
where necessary, correct the appraisal
data. Consequently, the lender is able to
access the UCDP Portal and receive the
status and findings, correct and/or
revise appraisal file submissions, and
request overrides when the appraisal is
not accepted by the UCDP Portal. There
is a Search function and also a report
feature, each of which makes it easier
for the lender to review uploaded data.
Training
Training manuals are available for the
UCDP Portal. These most important
training guides are recorded tutorials,
called Using the Uniform Collateral
Data Portal and Submitting Appraisal
Data Files to the Uniform Collateral
Data Portal Tutorials and a General User
Guide. Furthermore, Fannie Mae and
Freddie Mac have a joint UCDP Support
Center, which can be reached by calling
(800) 917-9291.
continued on page 21
Landmark $25 Billion
Agreement Reached With
Top Five Servicers
U.S. Attorney
General Eric
Holder, U.S.
Department of
Housing &
Urban Development (HUD) Secretary
Shaun Donovan, Iowa Attorney General
Tom Miller and Colorado Attorney
General John W. Suthers have
announced that the federal govern-
ment and 49 state attorneys general
have reached a $25 billion agreement
with the nations five largest mortgage
servicers to address mortgage loan serv-
icing and foreclosure abuses. The joint
agreement is the largest federal-state
civil settlement ever obtained and is the
result of extensive investigations by fed-
eral agencies, including the U.S.
Department of Justice (DOJ), HUD and
the HUD Office of the Inspector General
(HUD-OIG), and state attorneys general
and state banking regulators across the
country. The joint federal-state group
entered into the agreement with the
nations five largest mortgage servicers:
Bank of America, JPMorgan Chase, Wells
Fargo, Citigroup and Ally Financial Inc.
(formerly GMAC).
This agreement holds mortgage ser-
vicers accountable for abusive practices
and requires them to commit more
than $20 billion towards financial relief
for consumers, said Holder. As a
result, struggling homeowners through-
out the country will benefit from
reduced principals and refinancing of
their loans. The agreement also
requires substantial changes in how ser-
vicers do business, which will help to
ensure the abuses of the past are not
repeated.
The joint federal-state agreement
requires servicers to implement new
mortgage loan servicing standards and
to commit $25 billion to resolve viola-
tions of state and federal law. These vio-
lations include servicers use of robo-
signed affidavits in foreclosure pro-
ceedings; deceptive practices in the
offering of loan modifications; failures
to offer non-foreclosure alternatives
before foreclosing on borrowers with
federally insured mortgages; and filing
improper documentation in federal
bankruptcy court.
A final agreement can play an
important role stabilizing and providing
certainty and confidence to the housing
and mortgage markets, said David H.
Stevens, president and chief executive
officer of the Mortgage Bankers
Association (MBA). With all the rumors
and speculation surrounding these
negotiations behind us, it is now imper-
ative that policymakers, lenders, ser-
vicers and other stakeholders work
together on policies and initiatives that
will allow us to get the housing market
on the road to recovery.
Under the terms of the agreement,
the five servicers are required to collec-
tively dedicate $20 billion toward vari-
ous forms of financial relief to borrow-
ers. At least $10 billion will go toward
reducing the principal on loans for bor-
rowers who, as of the date of the settle-
ment, are either delinquent or at immi-
nent risk of default and owe more on
their mortgages than their homes are
worth. At least $3 billion will go toward
refinancing loans for borrowers who
are current on their mortgages but who
owe more on their mortgage than their
homes are worth. Borrowers who meet
basic criteria will be eligible for the refi-
nancing, which will reduce interest
rates for borrowers who are currently
paying much higher rates or whose
adjustable rate mortgages are due to
soon rise to much higher rates. Up to $7
billion will go towards other forms of
relief, including forbearance of princi-
pal for unemployed borrowers, anti-
blight programs, short sales and transi-
tional assistance, benefits for service
members who are forced to sell their
home at a loss as a result of a
Permanent Change in Station order,
and other programs. Because servicers
will receive only partial credit for every
dollar spent on some of the required
activities, the settlement will provide
direct benefits to borrowers in excess of
$20 billion.
The servicers are required to fulfill
these obligations within three years. To
encourage servicers to provide relief
quickly, there are incentives for relief
provided within the first 12 months.
Servicers must reach 75 percent of their
targets within the first two years.
Servicers that miss settlement targets
and deadlines will be required to pay
substantial additional cash amounts.
In addition to the $20 billion in
financial relief for borrowers, the agree-
ment requires the servicers to pay $5
billion in cash to the federal and state
governments. $1.5 billion of this pay-
ment will be used to establish a
17
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By Dave Hershman
Let me make an
assumption here. You
are a producing man-
ager or owner. This is
a pretty good bet
because more than
80 percent of the production managers
and owners in this industry also pro-
duce themselves. And the majority of
the income earned by these producing
mangers or owners is derived from per-
sonal production. The final number
may vary, but typically more than 50
percent of the income comes from orig-
inating loans, rather than base salaries,
overrides and/or profits.
As I mentioned last month, a pro-
ducing manager has about five full-
time jobs. What are they you may ask:
I Producing loans;
I Recruiting loan officers and opera-
tions personnel;
I Hiring and on-boarding successful
recruits;
I Supporting those supervised
including marketing and processing
support, training and coaching;
I Handling administrative tasks,
which can include anything from
compliance tasks, to reports to fight-
ing fires.
Thats a great deal for one person.
That is exacerbated by the fact that
more than 50 percent of a managers
time is likely to be taken up by person-
al production. It makes sense that if
more than 50 percent of their income
comes from personal production, they
are going to dedicate more than 50
percent or more of their time to this
task. Thus, this is how the numbers
shake-out20 percent to 50 percent of
their time is focused upon four very
important jobs. All of which could be
full-time jobs for an ordinary citizen.
What does this all mean? For the
average manager, it likely means that
four of these jobs are not going to get
accomplished adequately. Lets take an
example such as recruiting. The aver-
age manager will not recruit the num-
ber of loan officers they would like to
have. Even more important, the loan
officers they do recruit are not likely to
be the quality necessary because there
is not enough time dedicated to the
recruiting and hiring process. What
makes this so onerous is that if the
quality of the loan officer coming in is
less than what is expected and there is
not enough time for coaching and
training, the results will not be there.
That leaves even more time to be spent
in the fighting fires category, which
could mean anything from rescuing
poorly originated deals to firing inept
and poorly supported originators.
Does this sound like you? If it does,
Do You Have Enough Time
to Manage?
you are probably thinking: Dave, I
know all about this problem. You have
told me nothing.
The issue is ... how do I get better at
the other tasks? That is a reasonable
question. And it is very important for
me to help guide you so that there is
some sort of light at the end of the tun-
nel. I certainly am not going to solve the
issue in one column, but we will work
our way towards solutions, bit-by-bit.
All goals are achieved one step at a
time, and this will be no different.
Basically, there are a few keys that
will help you get more accomplished in
a world in which you have a finite
amount of time and too many things to
accomplish correctly ...
Planning
If you dont know where you are going,
you will not know when you get there.
So, first you need to make some deci-
sions regarding what you want to
accomplish. If your goal is to hire more
quality loan officers, are you willing to
move this objective up in priority? I can-
not lie to you here ... while I may give
you tips regarding how to be more
effective with your time, you cannot
move something up in priority without
sacrificing somewhere else. There is
only a limited amount of time in each
day. With this balance in mind, only you
can make this decision. If you are happy
spending 70 percent of your time in
personal production and limiting the
results elsewhere, then so be it.
Delegation
Making decisions regarding prioritiza-
tion leads you to another very impor-
tant question. You not only need to
decide what is important, but what is
more insignificant. It is not a matter of
just eliminating personal production in
favor of recruiting or coaching. What
areas within the production process
represent the best use of your time?
What areas can be performed by anoth-
er entity? Delegating actions can
include everything from hiring a loan
officer assistant to employing a market-
ing firm to make sure your entire
sphere is reached with value on a regu-
lar basis. Are you spending time obtain-
ing conditions? Can someone else be
accomplishing this task instead of you?
Anything you can hire out at a low
salary may be a ripe area for an evalua-
tion. This does not mean that you hire
everything out, but it does mean that
you can make more intelligent time
management decisions.
Synergy
Synergy is an overused word. However,
if you want to accomplish more in less
time or with less monetary resources,
the implementation of synergistic prin-
ciples is absolutely essential. There are
so many examples of these principals
and we will be examining these in
upcoming columns. In my book,
Maximum Synergy Marketing, I give
seven rules of synergy marketing. One
which is very important to take note of:
Every task you accomplish should
achieve another objective. This is the
rule of multi-tasking. If you look at
the five separate jobs listed above,
there is no doubt that the list is oner-
ous, especially if you consider these
completely separate jobs. But if you
understand that accomplishing one
task can also move you closer to anoth-
er objective, the equation changes sig-
nificantly. For example:
I Thinking about hiring an assistant? Is
it possible that your assistant could
be trained at the same time to
become your next loan officer
recruit?
I Spending a lot of time marketing for
loans? Is there a way to also market
for loan officers also using the same
advertisements?
The examples we could present are
limitless, but these two should give you
a general idea.
The elimination and
prevention of mistakes
This is a very important and difficult
task. Mistakes cost you time fighting
fires and accomplishing other unneces-
sary tasks. You will find most of these
are caused by issues existing within the
front end of the system. Many times,
these issues are exacerbated by the fact
that you do not have enough time to do
things right the first time.
I Dont have enough time to take a
thorough loan application? The
things you miss might very well
cause explosions on the other end.
I Dont have enough time to train loan
officers on the importance of a great
loan application? Again, the results
are likely to be fires and more fires.
I Have a loan officer that is taking too
much of your time with little or no
results? The longer you stay with that
mistake, the more it can hurt the
other aspects of the process.
Some of these areas will definitely be
focused upon in future columns. But
for now, we have laid the issues out on
the table. The solutions are simple.
However, they are not easy to imple-
ment. It takes discipline and a plan.
Hopefully, this discussion has you
thinking about possible solutions to the
five jobs dilemma. I would love hear
your reaction, suggestions and com-
ments. Just e-mail them to me at
dave@hershmangroup.com.
Dave Hershman is a top author in the
mortgage industry with seven books pub-
lished, as well as hundreds of articles.
Dave has delivered hundreds of keynote
speeches, seminars and schools for the
industry as well. He may be reached by
e-mail at Dave@HershmanGroup.com or
visit OriginationPro.com.
If you dont know where
you are going, you will not know
when you get there.
e-mail: sales@calyxsoftware.com
visit: www.calyxsoftware.com
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Over the last decade Ive spent in this
industry, Ive found that the greatest
reward and growth for my business has
been from the feedback of clients and
testimonials. Being in an industry
which offers a service rather than just a
product means we must always strive
to make our level of service excellent.
After all, we have control over our
actions and reactions, and how we han-
dle our clients during the loan process
... do we not? We also have the ability
to create systems and adapt to the
needs of our clients under any lending
climate, dont we?
The quality of our service can only be
determined by our clients through their
experience with us during the applica-
tion and loan process. There is absolute-
ly no doubt that communication is the
most important factor in what we deal
with on a daily basis. This is not a skill
you should have, its simply a require-
ment. Having consistent and accurate
communication will allow you to gain
customer loyalty, trust and respect. In
addition, it will allow you to get the most
beneficial feedback available to cus-
tomize your services for the very clients
youre working to attract and retain.
Feedback helps you build, while tes-
timonials help you grow. You might
think things are going fine in your busi-
ness, but it really doesnt matter what
you think. It only matters what your
clients or potential clients think.
Obtaining vital feedback will help you
improve or update sections of your
loan processing systems in order to cre-
ate the most favorable client experi-
ence possible. Our industry and lend-
ing climate is constantly changing, and
we must always be prepared to listen to
clients and implement change in order
for them to successfully understand
and navigate through the process.
Testimonials are extremely powerful
and a free source of marketing. Nothing
promotes your services better than testi-
monials from past clients. You are
almost guaranteed that if someone is
Feedback Fuels Your Business
Visit www.NAMB.org/legconference
for details!
The number one reason you should attend this event is
the satisfaction of knowing you are doing your part to
ensure that mortgage broker issues are heard on
Capitol Hill. You are the best spokesperson for our
issues. Your participation benefits you, the industry and
your clients as a whole, by strengthening the brokers
presence in the halls of Congress.
Highlights Will Include:
I Mortgage industry trade association panel discussion featuring representatives
from NAMB, the Mortgage Bankers Association (MBA), the National Association of
Realtors (NAR) and the National Association of Home Builders (NAHB)
I A closer look at the powers of the Consumer Financial Protection Bureau
(CFPB) and what they will be looking for in their audits
I Loan originator (LO) compensation and the impact of HR 2509, the Preserving
Consumers Mortgage Origination Choices Act of 2011, sponsored by Rep.
Gary Miller (R-CA)
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Sunday-Tuesday,
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Be prepared to go to the Hill!
Includes Advocacy 101 training:
General synopsis and "Question & Answer"
on the best ways to communicate NAMB's
talking points with your congressional leaders
in an effective manner.
willing to provide you with a testimonial
they are also referring you to family and
friends. You must ask for testimonials,
not just referrals. Each loan closing
should include a closing package with
handwritten thank you, business cards
and promotional materials. It should
also include a customer survey and
request for both written and online testi-
monials. Use these client testimonials in
your marketing and to attract new
clients, but never attempt to use self-gen-
erated or fraudulent testimonials.
Another added benefit of testimonials
is that they are extremely motivating.
They help remind you to be thankful and
appreciative for the clients youve met
and been able to assist. It also allows you
to confirm you are making a difference
by meeting personal goals in customer
satisfaction by exceeding their expecta-
tions. Always remember that most con-
sumers are doing their research on serv-
ice providers, especially in the mortgage
industry. Let them find something special
when researching you!
Tip of the month
If you are a mortgage loan originator
(MLO) looking for a company to partner
with, take the same approach as your
clients do. Before even interviewing
with a company, check their ratings
and customer feedback online and
through any and all channels available.
If you see a consistent negative trend or
complaints, dont even bother inter-
viewing. There is no excuse for repeat
offenders. Do yourself and your clients
a favor by just moving on and working
by reputation and referral when consid-
ering a new home base.
Andy W. Harris, CRMS is president and
owner of Lake Oswego, Ore.-based
Vantage Mortgage Group Inc. and 2010-
2011 president of the Oregon Association of
Mortgage Professionals. He may be reached
by phone at (877) 496-0431 or e-mail
aharris@vantagemortgagegroup.com or
visit AndyHarrisMortgage.com.
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regulatory compliance review continued from page 16
What to expect
from lenders
Lenders will require, at minimum:
I The Submission Summary Report
(SSR) from the UCDP Portal must
state that the submission status was
Successful.
I The UAD Compliant Appraisal must
be submitted to Fannie Mae and
Freddie Mac and must be
Successful for each.
I The Appraisal must clearly state on
the bottom of the appraisal the fol-
lowing UAD indicator, UAD Version
9/2011.
Important dates
I Dec. 1, 2011 (loan application date):
Lenders must deliver fully UAD-com-
pliant electronic appraisal report
data (if appraisal required) and
expanded loan delivery data.
I March 19, 2012 (loan delivery date):
Lenders must submit fully UAD-com-
pliant electronic appraisal report
data (if appraisal required) to the
UCDP Portal.
I July 23, 2012 (loan delivery date):
Loan delivery data must be provided
in industry-standard ULDD format
(unless manually entered in Loan
Delivery). All loans delivered to
Fannie Mae on or after July 23, 2012
with an application date on or after
December 1, 2011, must meet the
ULDD requirements.
I Nov. 26, 2012: Additional XML Data
Requirement for Delivery: pursuant
to the Dodd-Frank Wall Street
Reform and Consumer Protection
Act, the Securities and Exchange
Commission (SEC) issued a rule which
requires all securitizers, including
the GSEs, to publicly disclose infor-
mation regarding ABS loan repur-
chase requests.
12
One of the require-
ments of this rule is to disclose the
identity of the entity funding the
applicable loan. Therefore, to com-
ply with the SEC rule, the GSEs will
require lenders to deliver these addi-
tional data points.
Jonathan Foxx, former chief compliance
officer for two of the countrys top pub-
licly-traded residential mortgage loan
originators, is the president and manag-
ing director of Lenders Compliance
Group, a mortgage risk management
firm devoted to providing regulatory
compliance advice and counsel to the
mortgage industry. He may be contacted
at (516) 442-3456 or by e-mail at
jfoxx@lenderscompliancegroup.com.
Footnotes
1The following Fannie Mae and Freddie Mac
documents were amongst those issuances con-
sulted in preparation of this article: FHFA
Announcement, 12/14/11; Lender Letter LL-2011-
09, Extension of the Uniform Loan Delivery;
Dataset; Implementation Date; Uniform
Mortgage Data Program, Registration Checklist,
UCDP 11/11; Reminder: Key UMDP Requirements
Go Into Effect on December 1, 2011, 11/29/11;
Uniform Collateral Data Portal (UCDP), FAQs,
10/25/11; Uniform Collateral Data Portal
Reference Series for the Lender Admin: 1-Lender
Admin Registration, 08/11; Uniform Collateral
Data Portal Reference Series for the Lender
Admin: 2-Managing Business Units, 05/11;
Uniform Collateral Data Portal Reference Series
for the Lender Admin: 2-Managing Users, 05/11;
Uniform Collateral Data Portal Reference Series
for the Lender Admin: 4-Managing Lender Agents,
05/11; Uniform Collateral Data Portal, Overview,
11/17/11; Getting Ready for UCDP Job Aid,
10/24/11; and Uniform Collateral Data Portal
(UCDP), General User Guide, 08/11.
2See the Uniform Collateral Data Portal page:
efanniemae.com/sf/technology/commitloandel/ucdp.
3At this time, MISMO Version 3.0 does not pro-
vide a framework for appraisal report data.
Fannie Mae and Freddie Mac are transitioning
their single-family loan delivery file formats to the
industry standard MISMO Version 3.0 Reference
Model and changing the data elements required
at the time of loan delivery.
4See Lender Letter LL-2010-15.
5UAD forms indicate a version date of UAD
Version 09/11, in addition to the current March
2005 form date, while the previous form will have
a March 2005 form date. An appraisal report is
considered to be UAD compliant if it is completed
in accordance with Appendix D, UAD Field-
Specific Standardization Requirements of the UAD
Specification.
6While mortgage brokers are not responsible
for submitting the appraisal to the UCDP Portal,
they must be aware that if the lender submits the
appraisal and does not receive a Successful sub-
mission status from both Fannie and Freddie, the
loan is not likely to be eligible for funding/pur-
chase by the lender.
7For registration instructions, see Uniform
Collateral Data Portal Reference Series for the
Lender Admin: 1- Lender Admin.
8GSE appraisal forms include: Uniform
Residential Appraisal Report (Fannie Mae
1004/Freddie Mac Form 70)-UAD; Manufactured
Home Appraisal Report (Fannie Mae
1004C/Freddie Mac Form 70B); Small Residential
Income Property Appraisal Report (Fannie Mae
1025/Freddie Mac Form 72); Individual
Condominium Unit Appraisal Report (Fannie
Mae 1073/Freddie Mac Form 465)-UAD; Exterior-
Only Inspection Individual Condominium Unit
Appraisal Report (Fannie Mae 1075/Freddie Mac
Form 466)-UAD; Exterior-Only Inspection
Residential Appraisal Report (Fannie Mae
2055/Freddie Mac Form 2055)-UAD; Individual
Cooperative Interest Appraisal Report (Fannie
Mae Form 2090); and Exterior-Only Inspection
Individual Cooperative Interest Appraisal Report
(Fannie Mae Form 2095).
9Vendor lists are available at eFannieMae.com
and FreddieMac.com.
10See Veros.com.
11The maximum size per appraisal data file is
12 MB for a PDF-only and 15 MB for an XML file
format that contains an embedded PDF. For mul-
tiple appraisal files at one time, the total com-
bined file size limit is 100 MB.
12SEC Rule 15G(a)-1.
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ach month, National Mortgage
Professional Magazine will focus on
one of the industrys top players in
our Mortgage Professional of the Month
feature. Our readers are encouraged to
contact us by e-mail at newsroom@nmp-
mediacorp.com to be considered for a
future Mortgage Professional of the
Month feature article.
This month, we had a chance to chat
with Raymond Bartreau, current president
and chief executive officer of Best Rate
Referrals. A resident of Las Vegas, Nevada,
the 30-year-old Bartreaus Best Rate
Referrals has been in business for more
than seven years, specializing in direct mar-
keting services, ranging from mortgage
leads, loan modification leads, mailing
lists, mortgage mailers, and much more.
Best Rates team of marketing professionals
has more than 30 years experience in cre-
ating profitable marketing campaigns for
brokerages nationwide. Raymond is also
the chief executive officer of
HARPMortgageLeads.com. Raymond has
made the Inc. 500 list on two separate occa-
sions with Best Rate Referrals and has also
been named to National Mortgage
Professional Magazines 40 Under 40 list
on two occasions.
How did you first get involved in the
mortgage business?
I got started in the industry in 2002 as a
call center manager. While attending
Northern Arizona University, I managed a
large outbound call center for Direct TV.
It was there where I gained a great deal of
experience and was recruited by a mort-
gage company in Vegas to run a small call
center. When I first started, I barely knew
what an interest rate was.
During that time, were you seeing any
great opportunities that others may
have been overlooking?
Not really. The broker that we had at that
time ran a chop shop of loan officers. They
were using an old school approach. They
werent using any media, just their out-
bound call center. It wasnt that I saw
what everyone else was missing, I saw
what they were missing. They were paying
loan officers well under what I thought
they should be paid, and I wasnt allowed
to grow within the company and become
a loan officer. That is what catapulted me
to look and see what else was out there.
How valuable do you think your time
spent on the frontlines is to your
clients?
I started initially by seeing what it took
to get a client in the market. I really
know what its like to reach out to the
consumer and know how to have a
long-standing relationship. Once I left
the call center gig, I took what I learned
and began originating loans for a local
bank. I was able to hire my own tele-
marketers to originate leads for me.
Thats really what I learned there, and
of course, doing loans for the next three
years thereafter. From the middle to the
end of the recent refi boom, I was able
to really connect with homeowners.
When I transformed into marketing,
loan officers were marketing them-
selves, and I really could connect to
what they were doing. I think it helped
a tremendous amount.
How important is a first impression?
Very important. Any time you are going
to market your brand or service to a
consumer or buyer, depending on what
that product is, you often only get one
impression. There is competition out
there and you have to strike quickly,
and do everything professionally and
what is right for the client. I think if you
do that, not only do you stand a better
chance of landing that targeted client,
but youre also going to get a long-term
relationship and referrals from that
client as well. For me, its all about long-
term relationships and they dont start
long termthey start with the first
impression. You dont get a long-term
relationship without making a good
first impression.
What do you think is an acceptable
response time for Web leads and direct
mail leads?
There are many factors to consider when
discussing Web leads and direct mail
leads, and there are many options when
you are looking at both verticals. With
direct mail, you have standard versus
first-class postage. Youve got different
types of databases, different types of
response methods, whether its driving
them through the phone or through the
Internet. There are a lot of different
options on the mail side. I suggest they
send first-class on a Friday so their phones
will be ringing on Monday. Monday-
Wednesday is when your mail is going to
be hitting within two to five business days.
Thats a good response time with mail.
On the Web side, the only factors you
have to consider are if the lead was
exclusive or if it is from a shared source.
And then, above and beyond that, how
high is the quality of the lead so when
you are considering response ratios
from the Internet, they can vary. If its
your own organic traffic or if its from
leads coming from an organic place,
you can expect the response time
immediately because there are people
doing work to get them. You have to act
on those leads right away. As you move
into more of a shared platform, and a
lower type of lead quality, you typically
see a lower response and less revenue
per loan as well. There are choices in
the Internet space, when you find a
good provider, stick with them even if
they have a rough period (quality can
dip for a number of reasons), give them
feedback often (which helps them catch
any issues that can drive that quality
dip) and never put all of your eggs in
one basket (try multiple sources).
How do you inspire your employees to
deliver such great customer service?
Since day one, I have wanted to make
every single client happy. I think as I
brought in people and trained them,
they took that philosophy on and they
really care. Its really a fun time in our
office when we get re-orders. Our
perimeters are set around our client
retention percentages. Revenue is num-
ber two. Client retention percentages
remain first and foremost for us. Lastly,
my crew does not get paid unless they
retain clients. If you are a marketing
agent on a very small base and you are
paid primarily on your performance,
client retention determines how much
you will be paid.
If you just pay large salaries, those
employees will not care about their
clients. Weve lost salespeople with
great potential because they wanted
salary and lower commissions, but we
really believe that people can make a
lot of money in the marketing industry
by retaining relationships. I have peo-
ple doing that right now on low to no
salaries. So you just offer incentives by
not paying them salaries and pay them
based upon client retention. Its a pret-
ty smooth running engine over here
now, and Im pretty happy about it.
How are you helping your clients prepare
to market with the advent of HARP 2.0?
There is a lot of education were trying
to put out. In addition, there is a lot of
research that were doing, including
data analysis and trying figuring out the
best ways for these guys to market
themselves. There are various channels
and a lot of options. We really have a
solid platform put together on the
direct mail side for the HARP program,
whereas, we have several pieces in
place that are compliant that we feel
from our past has gotten great respons-
es from other products the way theyre
Raymond Bartreau, Founder/CEO
Best Rate Referrals and HARPMortgageLeads.com
There is competition
out there and you
have to strike quickly,
and do everything
professionally and
what is right for
the client.
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laid out. We feel we can get a great
response now where the current mort-
gage rates are. Educating our clients
about direct mail and all of direct
mails pros and cons is the best way to
do it. We are primarily handling their
job from A to Z to keep things flawless.
Along with data analytics, there is
the callable side for everybody in the
universe that fits the HARP 2.0 criteria.
Approximately 10 to 12 percent of
those people have phone numbers
after a Do-Not-Call scrub, and you can
actually reach out to those folks by
phone. We have a dialer company that
we can get to our clients, and then we
train them on how to make the call. We
utilize scripting, dispositions and rebut-
tals just different things that can
help them to be successful with a
HARP-related call because a lot of peo-
ple like direct mail, but never call the
list theyre mailing to as they dont real-
ize they can call.
We try to train our clients to get over
that hurdle of the un-fun factor and
realize that there is money to be made
there. There is a big audience that has
yet to realize this program. We in the
mortgage industry know its coming, but
the consumers dont and it will start
being talked about and it will get hot. We
train our clients on how to filter their
databases and train them on how to hit
their current and referral client bases
and referral partners with educational
pieces. We do it quickly because this is
going to spread fast and the first person
who gets referred to a homeowner as a
professional is probably going to be the
one who gets the loan.
If you want to get the market share
you desire, get out to your clients and
referral partners, and provide your
referral partners with information that
they can get out to their people. If you
get materials out there and send these
materials to your circle of contacts, you
will get business back from it.
You must also create a Web presence.
There are a lot of lender-direct companies
marketing for HARP 2.0 candidates that
can help you. In fact, we have a couple of
Web property directories that will be rank-
ing very high on Google. Lender directo-
ries are a good place to be. They are cheap
to be on, and are limited in terms of how
many people are let on per state. Get
aggressive and get your name out there.
There are many channels to explore:
Direct mail, social media, free networking,
outbound call centers, the media, your
own circle of friends, TV and radio
there are so many apples across the board
that you kind of have to do a combination
of things. I believe your current past client
database is the most important. Hit them
first, and educate them with materials
that they can share with their friends.
Dont make your goal just to educate
them one on one. Make it your goal to
educate them so that they can pass that
knowledge along to the people they
know. Dont work twicelet them work
for you and then combine that with some
additional marketing if you can stand
doing more loans every month, whether
its direct mail or Internet traffic.
How has direct response changed over
the past 10 years?
The landscape has changed drastically.
From the time I got into it, things were
hectic. There was a lot of call center
action. There were some TV and radio
spots, and direct mail was predomi-
nant. Ten years ago, the Internet was
really just getting going in terms of seri-
ous traffic and volume, and people
were just starting to figure out how to
generate leads online. Things have
changed quite a bit, with technology
leading the way. There are still some
old-fashioned ways of marketing, such
as putting ads in newspapers, cold call-
ing and utilizing direct mail that are still
in play. But technology has partnered
with these old-fashioned ways and has
allowed for a better response ratio with
a targeted accurate marketing cam-
paign so that your dollars are spent
more wisely.
Ten years ago, lead management sys-
tems were not too well-known. Now, if
you are generating leads to a group of
loan officers or branches on whatever
level youre on, its almost unheard of to
not have a lead management system to
make sure that your agents are staying
in front of those leads repeatedly. Not
only does it let you keep all of your
agents in front of you, but it also tracks
what your agents are doing as well.
Everything has become more efficient
with technology.
Outbound call options are more limit-
ed now. Ten years ago, you could pretty
much call anybody, but now you are lim-
ited to 10 to 12 percent of anybody good
for the criteria for your product. Your
approach back in the day of mailing to
entire neighborhoods, and things of that
nature, is pretty ineffective these days. For
example, in California, Arizona and
Nevada, there are too many people in
neighborhoods riddled with foreclosures.
You are wasting a lot of money just mar-
keting to entire neighborhoods. Targeted
marketing has become more predominant
and more updated.
When you look back at your career,
what do you feel is your greatest
accomplishment?
I have been very fortunate to reach a lot
of the milestones Ive set. Overall, I guess
just taking my company from a start-up
and within three years, making the Inc.
500, and then duplicating that feat again
a year later is a big accomplishment. The
fact that we continue to grow ourselves is
probably the biggest accomplishment
that I can tell my kids about when they
get older. I have been able to grow at a
consistent basis and have retained my
client base during a very difficult and low
time in the industry we service.
What are some of the issues that keep
you up at night?
I dont really have a lot of concerns. The
things that keep me up at night are just
the thought of growth our exponen-
tial growth. I really enjoy helping other
companies grow in addition to my own.
That may be why my company is still
around we really care. When we get
another client re-order and they say to
us, That last campaign was great we
spent $5,000 and made $40,000 lets
do it again! Theres a big satisfaction
when a client keeps coming back to you
week after week, month after month.
Thats what keeps me up the fear of
not having that client retention. We have
a system in place that will keep us doing
this for a very long time. We are going to
continue to grow and acquire more com-
panies and are going to continue to take
more real estate in this business because
the engine is just set up properly with the
right staff in place to run it.
Of all the different areas you cover
related to marketing, what has the
highest return-on-investment (ROI)?
If you are just looking at a CPA (Cost
Practice Acquisition) basis, it has to be
aged Internet leads. From a direct mort-
gage standpoint, you can buy a set of
aged Internet data for under $1 per
lead and you can call through 100 leads
and get two to five or seven or eight
deals out of the new HARP 2.0 program
if you targeted the leads properly.
Worst-case scenario if you are paying
$1 or $2 per lead, and get one deal our
of 100, the cost difference is $100. Aged
Internet leads are the cheapest form,
but it does require some effort. You
must put in the work involved.
If you want to look at what is the
absolute cheapest way to market your-
self, it is simply building relationships.
Outside of direct marketing for a second,
just building relationships with real
estate agents is vital. Real estate agents
all have goals. You can help them reach
their goals and they can help you reach
yours. Financial advisors, CPAs you
have to build relationships with the peo-
ple who are dealing with current and
potential homeowners on a day-to-day
basis. The better you treat your referral
partners, the more you are going to
retain them, the better you are going to
be and the more business you are going
to get. Just be selective on who you want
to work with because your time is valu-
able and what you give out is valuable
that is always going to be your cheapest
acquisition.
What we are doing as a company for
our clients is building platforms and we
have some built that are generating
leads for people looking to buy a house
or sell a home. Our mortgage partners
are buying this traffic for themselves
and then work to see if they can qualify
anyone from this data to work with
their real estate partners. I have some
guys sharing their data with three dif-
ferent real estate guys, thus leveraging
their marketing dollars to really build
relationships all over town.
Are you big on setting goals and estab-
lishing a business plan?
If you are not goal-oriented, you are
never going to get to where you want to
be. If you dont know where you want to
be, youd better figure it out. Its a dog
eat dog world out there, and youre
about to see the big gold rush in the
mortgage industry, so set yourself some
goals to reach. In our company, our
goal is client retention, and then rev-
enue. If our client retention ever dips
below the 70 percent mark, then weve
got big issues! I dont even look at rev-
enue and dont care about revenue
until the retention numbers go back up
to a comfortable 75 to 85 percent.
I do marketing for a living, and
building relationships is my bread and
butter. You should look at your busi-
ness no different. Your referral partners
should be happy and 70 percent of your
referral partners should be sending you
business every month. If they are not,
somethings wrong. Either you have the
wrong referral partners, or youre not
treating them how they should be treat-
ed. Fix it. Make sure that 70 percent of
those you associate with are sending
you a deal every monthoutside of
your friends and family.
In the business world, 70 percent of
the people you are working with should
be sending you a deal each month, or
whatever percentage you feel comfort-
able with. Just set a goal because that
way, you are eliminating the riff raff
and the time wasted. Only focus and
spend your time on the people who are
going to build your business and help
you make money.
In terms of a business plan, figure out
how many units of business you want to
do per month and set minimum goals.
Has any book or person had a profound
impact on your life?
I was never really motivated by books or
motivational speakers. Ive never been a
big rah rah guy. There have been a few
people whom Ive met in working at call
centers who have given me the framework
for a great work ethic. You dont work if
youre not going to give 100 percent. If
youre not, youre in the wrong job and
you should move on to something else.
I dont come from old money and
want to retire early to take my daughter
around the world, build a family and
see all the places I want to see, thats
what drives me. Thats what influences
me its the places I want to go. For
some, the past motivates them. For me,
its the future that gets me excited!
When youre not working to help mort-
gage professionals, what do you do in
your spare time?
Im a single, full-time dad. When my
daughter Lexy is with her mother, I like
to just get out and enjoy life. I like to
travel, take in sporting events, and am
just a normal guy that really likes busi-
ness, loves life and lives for being a dad.
Any closing comments?
Dont sell yourself short, the next 12 to
18 months is going to be a lot of fun in
this industry, so enjoy it. A lot of you
have been waiting for this mini-boom,
so take advantage of it. However, also
think long-term and make sure that
your balance of refi versus purchase
sways to purchase when the HARP pro-
gram has only a few months remaining!
If you follow that formula, you will be
in business for a long time.
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Borrower Payment Fund to provide
cash payments to borrowers whose
homes were sold or taken in foreclo-
sure between Jan. 1, 2008 and Dec. 31,
2011, and who meet other criteria. This
program is separate from the restitu-
tion program currently being adminis-
tered by federal banking regulators to
compensate those who suffered direct
financial harm as a result of wrongful
servicer conduct. Borrowers will not
release any claims in exchange for a
payment. The remaining $3.5 billion of
the $5 billion payment will go to state
and federal governments to be used to
repay public funds lost as a result of
servicer misconduct and to fund hous-
ing counselors, legal aid and other sim-
ilar public programs determined by the
state attorneys general.
FinCEN to Require SAR
Filing and AML Programs
for Non-Bank Lenders
and Originators
The Financial Crimes
Enforcement Network
(FinCEN) has finalized
regulations that
require non-bank resi-
dential mortgage
lenders and originators to establish
anti-money laundering (AML) programs
and file suspicious activity reports
(SARs), as FinCEN requires of other types
of financial institutions.
FinCEN is closing a regulatory gap
by requiring non-bank mortgage
lenders and originators to develop anti-
money laundering programs and file
suspicious activity reports with
FinCEN, said FinCEN Director James H.
Freis Jr. Suspicious activity reports are
a critical source of information to law
enforcement and regulatory agencies in
their investigation and prosecution of
mortgage fraud and a wide range of
other financial crimes.
Based on FinCENs ongoing work
directly supporting criminal investiga-
tions and prosecutions, including in
connection with the Financial Fraud
Enforcement Task Force and recently
the Residential Mortgage-Backed
Securities Working Group as well as
other anti-fraud efforts, FinCEN
believes that the new regulations will
help mitigate some of the risks and
minimize some of the vulnerabilities
that criminals have exploited in the
non-bank residential mortgage sector.
Analysis of SARs reported in FinCENs
annual, quarterly and special fraud
reports, shows that independent mort-
gage lenders and brokers originated
many of the mortgages that were the
subject of bank SAR filings.
In a further step to combat fraud in
the residential mortgage markets,
FinCEN issued a proposal in November
2011 that would require the govern-
ment-sponsored enterprises (GSEs)
Fannie Mae, Freddie Mac, and the
Federal Home Loan Banksto develop
AML programs and file SARs with
FinCEN.
Taken together, the final rules issued
and the proposed rules issued in
November provide additional tools for
financial institutions and law enforce-
ment to hold scammers accountable for
their fraud and other financial crimes.
Among the many mortgage-related
scams FinCEN has identified in its
reports are false statement, use of straw
buyers, fraudulent flipping, flopping,
and identity theft. The new regulations
likely will significantly increase the
number of mortgage related SAR filings;
give law enforcement and regulators
more comprehensive data on specific
crimes; and provide government and
industry a more complete perspective
on mortgage related crime trends
nationwide.
Fixed Rates Remain the
Dominant Choice Among
Refinancing Borrowers
In the fourth
quarter of 2011,
fixed-rate mort-
gages (FRMs)
accounted for
more than 95
percent of refinance loans, based on the
Freddie Mac Quarterly Product
Transition Report. An increasing share
of refinancing borrowers chose to short-
en their loan terms during the fourth
quarter of 2011 as well. Of borrowers
who paid off a 30-year FRM, 43 percent
chose a 15- or 20-year loan, the highest
such share since the first quarter of
2003.
Fixed mortgage rates averaged four
percent for 30-year loans and 3.30 per-
cent for 15-year product during the
fourth quarter in Freddie Macs Primary
Mortgage Market Survey (PMMS), well
below long-term averages, said Frank
Nothaft, Freddie Mac vice president and
chief economist. The Bureau of
Economic Analysis has estimated the
average coupon on single-family loans
was about 5.2 percent during the fourth
quarter of 2011. Its no wonder we con-
tinue to see strong refinance activity
into fixed-rate loans.
Fifty-eight percent of borrowers who
had a hybrid adjustable-rate mortgage
(ARM) transitioned to an FRM during the
fourth quarter, while the remaining 42
percent chose to refinance into the
same type of product.
For borrowers motivated to refi-
nance by low fixed-rates, they could
obtain even lower rates by shortening
their term, said Nothaft. Compared to
a 30-year fixed-rate mortgage, the inter-
est rate on 15-year fixed was about 0.7
percentage points lower during the
fourth quarter. And for borrowers who
plan to remain in their current home
for only a few years, the hybrid ARM
allows for even a greater interest-rate
nmp news flash continued from page 16
By Andrew Weiss-Malik
Many of todays mortgage professionals have come to
expect paperless technology as a given when maneuver-
ing through the sometimes arduous process of complet-
ing a loan application. From online chatting to e-mail
updates, much of what takes place within the mortgage
industry can now be tackled from the comfort of our
own computers, but despite all these tech advancements, we still have a
lot of catching up to do. This is because just as it seems we have tackled
the latest tech products with ease, new products come in to play and take
predominant use over anything that is even the slightest bit slower or
more timeworn. One product that seems to be overtaking laptops as of
lately is the tablet.
In the simplest of terms, tablets can be considered a hybrid of laptops
and smartphones. From the angle of todays computer capabilities, tablets
allow for a touch-screen keyboard and can imitate both PCs and Macs. At
the same time though, tablets can also be synced with the users phone
contacts and can contain downloaded smartphone-like apps, the latter of
which offers nearly endless capabilities.
The tablet is quickly growing in popularity, and it is clear that the new
product is here to stay, but despite its positive and innovate influence
within the tech world, most industry professionals have yet to adopt the
tablet for their daily use of mortgage technology. And with a lack of pres-
ence from mortgage tablet apps, todays mortgage leaders are unable to
take full advantage of helping to refuel a housing market sill in recovery.
Fortunately, On the Go Technology LCC is helping to pave the way for the
next step in mortgage technology with the release of the first mortgage
system designed from the ground up solely for tablet usage: MobileLO.
MobileLO is the first true tablet-based 1003 application system avail-
able within the mortgage industry. This application allows the originator
to pull and review a borrowers credit report directly on the device. The
software also features the ability to export a FNMA 3.2 file directly to any
loan origination system. Further, the MobileLO tablet application allows
the loan originator to generate compliant federal and state-specific dis-
closures. Lastly, the borrower can sign using their finger, or a stylus, and
that signature will transpose on to the disclosure set generated on the de-
vice. Unlike computer-based or even smartphone-based mortgage appli-
cations, there is no need to be online and best of all, the application is
immediately available for download from the iTunes store at NO COST.
Originators who have not made the leap to tablet computing can still use
this system via their Web browser at MobileLO.com. MobileLO offers a
free membership with basic services and a premium membership for
those originators that want to experience all that mortgage tablet com-
puting has to offer.
While MobileLO offers a revolutionized way of completing mortgage
applications and pushing the industry further into the 21st Century, there
is still a long way to go to catch up to todays tech offerings. Tablets are the
future of technology. Envision all the tablet-based apps that have yet to be
created, which will further modernize mortgage technology. Taking this
into consideration, the mortgage industry will certainly have its place in
the forefront of ground-breaking business advances for years to come.
Check out the future of mortgage technology at MobileLO.com.
Andrew Weiss-Malik, chief operating officer at 360 Mortgage Group LLC,
is recognized as an industry leader in mortgage-technology innovation. He
utilizes his experience in capital markets, mortgage-product development
and efficient operations to expand the capabilities of mortgage bankers. At
360 Mortgage Group, Weiss-Malik has developed the most advanced whole-
sale technology platform in the industry. He may be reached by phone at
(866) 418-2997 or e-mail aweissmalik@360mtg.com.
SPONSORED EDITORIAL
Tablets:
The Future of
Mortgage Technology
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multiple states
Quality FHA/VA lender
Innovative technology
Direct access to your underwriter
Instant closing docs
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Wholesale Lending
savings. The initial interest rate on a
5/1 hybrid ARM was about 1.1 percent-
age points lower than on a 30-year
fixed-rate loan.
FHFA Launches Pilot
Program to Sell Fannie
Mae REO Properties for
Rentals
The Federal Housing
Finance Agency (FHFA)
has announced the
first pilot transaction
under the Real Estate-
Owned (REO) Initia-
tive, targeted to some of the hardest-hit
metropolitan areas in Atlanta, Chicago,
Las Vegas, Los Angeles, Phoenix and
parts of Florida. With this next step,
pre-qualified investors will be able to
submit applications to demonstrate
their financial capacity, experience and
specific plans for purchasing pools of
Fannie Mae foreclosed properties with
the requirement to rent the purchased
properties for a specified number of
years.
This is another important milestone
in our initiative designed to reduce tax-
payer losses, stabilize neighborhoods
and home values, shift to more private
management of properties, and reduce
the supply of REO properties in the
marketplace, said FHFA Acting
Director Edward J. DeMarco.
In order to ensure compliance with
applicable securities laws and regula-
tions, details of the sales announce-
ment will be sent to prequalified
investors per FHFAs Feb. 1 announce-
ment. Subsequently, investors who post
a security deposit and sign a confiden-
tiality agreement will gain access to
detailed information about the proper-
ties. At that stage, interested investors
must submit a comprehensive applica-
tion, which will be reviewed by an out-
side firm. Only investors who are quali-
fied through this rigorous process will
be eligible to bid.
We believe that this initiative holds
promise for providing support to local
neighborhoods that were especially
hard hit by the housing crisis and will
help meet the rising demand for rental
housing in many communities, said
Michael Stegman, counselor to the
Secretary of the Treasury for Housing
Finance Policy.
Average Home Price
One-Third Below Peak
2006 Levels
Fiserv Inc. has released
an analysis of home
price trends in more
than 380 U.S. markets
based on the Fiserv
Case-Shiller Indexes. The indexes are
owned and generated by Fiserv, a lead-
ing global provider of financial services
technology solutions, and data from
the Federal Housing Finance Agency
(FHFA). The double-dip in home prices
that began two years ago continued to
take home prices lower through Q3 of
2011, during which the average price of
a U.S. single-family home fell to a new
post-bubble low, declining 3.9 percent
compared to the year-ago period.
Current average home prices are now
33 percent below the 2006 peak, with
broad weakness across the U.S. Over the
past year, home prices fell in 337 of the
384 metro areas tracked by Fiserv Case-
Shiller. This trend in home prices was in
line with the forecast made by Fiserv
one year ago, which projected a year-
over-year drop of 5.5 percent.
Despite continued price erosion,
some metro areas saw significant home
price gains in the past year including
markets that were deeply affected by
the housing bubble and recession.
Examples include Detroit, Mich. (11.1
percent); Buffalo, N.Y. (6.7 percent) and
Fort Myers, Fla. (2.8 percent).
While prices continued to fall in
most markets, sales activity picked up at
the end of 2011, setting the foundation
for price stabilization in 2012, said
David Stiff, chief economist at Fiserv.
We stand by our projection that aver-
age U.S. home prices will move side-
ways in 2012. But we do anticipate that
increasing sales activity will begin to
drive small increases in prices in as
many as half of U.S. metro areas. Some
larger metro areas that escaped the
worst of the home price bubble, such as
Houston, Fort Worth and Salt Lake City,
can expect increases of one to three per-
cent. Many smaller metro areas, such as
Boise and Albuquerque, are forecast to
see increases of 4 to 6 percent.
The recovery in such markets, how-
ever, is not expected to be broad
enough to move the national average
this year. Fiserv Case-Shiller projects
that average U.S. prices will decline
another 2.7 percent by the third quarter
of 2012, compared to the year-ago peri-
od, before rising 3.8 percent by the
third quarter of 2013.
The other big story is the continued
improvement in housing affordability,
Stiff said. The monthly mortgage pay-
ment for the median-priced U.S. home
fell to $640, nearly 45 percent lower
than the housing bubble peak of
$1,150. That represents the lowest level
since 1994. Similarly, mortgage pay-
ments now account for only 14 percent
of monthly median family income, as
households made more progress in
repairing their balance sheets.
Home Prices Slow Rate
of Decline to 0.6 Percent
in November
Lender Process-
ing Services Inc.
(LPS) has an-
nounced that
its LPS Applied
Analytics division has updated its home
price index (LPS HPI) with residential
sales concluded during November 2011.
The LPS HPI summarizes home price
trends nationwide by tracking sales
each month in more than 13,500 ZIP
codes. Within each ZIP code, the LPS
HPI tracks five price levels from low to
high.
continued on page 33
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By David Lykken & Jon Traver
T
here was a song, United We
Stand, written by Tony Hiller
and Peter Simons that was
made popular by The Brotherhood of
Man and Sonny & Cher in the 1970s.
Based upon all that we have gone
through over the past two to three
years in our industry, there is a
greater awareness how we need to
stand united together more than
ever before. We have endured much
the implosion of the sub-prime
world, new regulations (loan origina-
tor [LO] compensation, appraisal
management companies [AMCs], the
2010 Good Faith Estimate [GFE], call
reports, etc.), heavy media criticism,
and a mass exodus of some top level
talent, we have taken quite a hit.
While 2012 is just getting going, we
are still fighting the good fight on
many fronts, both in an out of
Washington, D.C. So what does the
future hold for the industry we all
love so much?
Before we can move forward, it is
important to look back and under-
stand where we have been. Only
through self-reflection and under-
standing both our successes and fail-
ures, can we really grow and succeed
in the future. With the focus this
month on legislative issues, shining a
spotlight on our entire industry
becomes necessary to fully grasp the
challenges we have faced and will
continue to face in the future.
For the last 10-plus years, our
industry has been divided, fighting
amongst ourselves. There is a reason
why, throughout this entire crisis,
Realtors have largely been left alone,
and the mortgage industry has come
under intense scrutiny with ever
increasing efforts to rein us in.
Lets take a quick look at some of the
legislative challenges we are already
having to manage. As we go through
these, try to look at everything, not
from your own personal perspective,
but through the eyes of someone who is
simply A Mortgage Professional.
1. The 2010 GFE
In an effort to make the
homebuying purchase
easier for the client, we
were given a new, four-
page document. I think
anyone who has ever orig-
inated a loan will agree,
that this not only didnt
help matters, it hurt.
Where is the total pay-
ment? Where is the total
cash to close? Seller con-
cessions? And lets not
talk even start to talk
about the fact that a doc-
ument that is supposed to
help people shop
around cannot be given
out until a complete
application is received,
including a contract! Now
to be fair, there are a few
helpful parts to the docu-
ment, but by in large, I
think we all can agree it
has not achieved its stat-
ed goal.
2. AMCs and the
changes in the
appraisal industry
With both a real and per-
ceived problem with
appraisals and pressure
from the origination
level, an attempt was
made to clean this part of
our industry up. Yes, we
have been able to clean
up any issues with
regards to pressuring
appraisers to give value where it did not
exist. But at what cost did this come and
what new issues did we create? A seg-
ment of our marketplace that was
already underpaid, took
a big hit. Appraisers now
have to split their money
with management com-
panies that are simply a
buffer. Appraisers now
must split their money
with the companies
which mean they must
perform more to make
the same living. We have
lost so many of the top
appraisers and the ones
who have chosen to stay
simply dont have the
time to do as thorough a
job as is needed to deter-
mine a propertys real
value.
3. LO compensation
Okay, this section could,
and probably will,
become its own article
very soon. Whether you
simply want to talk about
how this rule takes capi-
talism out of the mort-
gage industry, has hurt
small business (both bro-
kers and small bankers),
or has harmed the level of
service that can be given
to a client, most everyone
agrees this has damaged
our industry. With a very
well-intentioned goal of
protecting the homebuy-
er, the exact opposite has
turned out to be true. All
of us working at the origi-
nation level can see how
this has hurt the consumer and yet sup-
port outside our industry for this and so
many other past and future efforts to
control us remains high.
Its Time to Come Together
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So, why are we
sitting here today,
fighting through all of
these issues, and
devoting so much time
and money to future
compliance problems?
We simply refuse or
fail to work effectively
together, and that has
to change.
David Lykken
If we all give a little,
we can all gain a lot.
Jon Traver
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It would not be fair to characterize
every change we have endured as a fail-
ure. There have been some successes
and improvements, even though
many of us still complain about those
as well.
The Nationwide Mortgage
Licensing System (NMLS) was long
overdue and needed in our industry.
We hold so much responsibility and
power within the real estate commu-
nity. Is it too much to ask that we are
properly trained, licensed and
tracked?
Many loan products, that we all
delivered to the marketplace are
now gone. No doc loans, 100 percent
stated/stated, option ARMs, etc.,
were completely misused by so many
and needed to go. And while there
should be room for select secondary
products, (self-employed, stated-
income, with 20 percent down and a
700-plus credit comes to mind), we
continue to struggle helping anyone
who doesnt fall within our tight lit-
tle box.
So, why are we sitting here today,
fighting through all of these issues,
and devoting so much time and
money to future compliance prob-
lems? We simply refuse or fail to
work effectively together, and that
has to change. While each market
segment has slightly different agen-
das, we are still playing the same
game. We must come together to
make this industry better, putting
aside our differences, and show
those who are putting these con-
straints on us that we can, and more
importantly, will, police ourselves.
Consider the National Basketball
Association (NBA) players as a group
and how they stick together. Do you
think the 12th man on the end of the
bench, making the league minimum
has the same agenda as Kobe
Bryant? Of course not, they each
have a completely different set of
problems and concerns. What about
how small market and large market
National Football League (NFL)
teams, who must compete with each
other every day, week, year, are able
to put that competition aside and
put rules in place that protect all
teams?
As an industry, we must come
together and work as a team.
Tomorrow we will compete for the
same loan, the same referral source,
the same dollar. But today, we have
to agree to work together to improve
the homebuying process for all con-
sumers. Trying to protect our own
self-interests has simply not worked.
It is time for a change in leadership,
and it must come from within and
from all levels and channels. We
must come up with our own ideas to
improve things, and then stand
together committed to helping the
customers we all serve.
Let this article serve as a plea to
everyone who reads it, from all cor-
ners of the mortgage world, it is time
to work together! Brokers, bankers,
banks everyone needs to under-
stand that if we dont, there will be
nothing left to fight about. The fin-
ger-pointing must stop and the hand
shaking and real ideas must begin.
Our consulting firm has been for-
tunate enough to work with many
successful companies and individuals
in the market. Lets wrap up with a
little challenge for everyone the
next time you are involved in a con-
versation about the great industry,
try talking through the issue, not
from your point of view, but the
point of view of the consumer. If we
all give a little, we can all gain a lot.
The alternative is to continue down
this path of fighting for our own self-
interests and the outsiders continue
to try and clean up our mess. It is
time to come together!
David Lykken is president of mortgage
strategies and managing partner with
Mortgage Banking Solutions. He has
more than 35 years of industry experi-
ence and has garnered a national rep-
utation, and has become a frequent
guest on FOX Business News with Neil
Cavuto, Stuart Varney, Liz Claman
and Dave Asman with additional
guest appearances on the CBS Evening
News, Bloomberg TV and radio. He
may be reached by phone at (512)
977-9900, ext. 10, or e-mail
dlykken@mortgagebankingsolutions.com
or dlykken@mbs-team.com. Jon Traver
is production consultantbranching,
recruiting and LO training for Mortgage
Banking Solutions. Jon has spent 12
years forging referral relationships
with builders and realtors for his own
mortgage company. He has extensive
experience working with branch com-
panies to grow their businesses through
branch and LO acquisition, as well as
building long-term business develop-
ment plans. Jon trains executives,
branch managers, and loan officers
how to redefine who they are and what
they do. He then helps them build a
game plan for taking that new knowl-
edge to the streets, including the execu-
tion. He may be reached by phone at
(512) 977-9900, ext. 112, (972) 467-
3990 or e-mail jtraver@mbs-team.com.
...the freedom to
originate!
nally
Dont take our word for it, read what our Rising Stars
at Americas Choice Say about us!
I started with Americas Choice as State
Manager at the beginning of 2011 and Im
glad I made the move. ACHL is an excel-
lent company to be associated with. This
company offers many of the opportunities
we had at previous companies and even
some of the same people weve all worked
with prior to coming to ACHL.
Dan Palumbo
25 years in business
This is the first company I have ever
worked for where what the recruiter told
me was 100% accurate!
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Your team is ABSOLUTELY THE MOST
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I really like this organization.
My only regret is that I didnt find
you sooner!
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9 years in business
Americas Choice gives you the tools you need
so you can Originate, Close and Get Paid!
www.achlonline.com
Give Jonathan Fowler, Director of National Production of
Americas Choice Home Loans a call at
713-821-9750
to learn how you can have a better, more rewarding career
To listen to David Lykkens online radio
show, Lykken on Lending, log on to
www.lykkenonlending.com.
28
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CoreLogic Launches
Residential Evaluation
Reporting Tool
CoreLogic has announced
a new data-enhanced,
appraiser-certified eval-
uation tool to help
mortgage lenders and
servicers address new requirements
issued in the 2010 Interagency
Appraisal and Evaluation Guidelines
(IAG). The Residential Evaluation Report
from CoreLogic provides an alternative
for federally-related mortgage transac-
tions in instances where the IAG permits
utilizing something less than a full
appraisal, but requires more than a
broker price opinion (BPO) or automat-
ed valuation model (AVM). The
Residential Evaluation Report from
CoreLogic provides six perspectives to
arrive at the propertys estimated mar-
ket value including a certified evalua-
tion of property value with an apprais-
ers opinion of value, a summary BPO,
two Automated Valuation Models
(AVMs) and two Indicated Value
Approaches (IVAs).
The new offering helps servicers meet
criteria set forth by the IAG, which were
issued by the five federal financial regula-
tory agenciesthe Office of the
Comptroller of the Currency (OCC), the
Board of Governors of the Federal Reserve
System, the Federal Deposit Insurance
Corporation (FDIC), the Office of Thrift
Supervision (OTS), and the National Credit
Union Administration (NCUA). The prod-
uct also meets the Uniform Standards of
Professional Appraisal Practice (USPAP) as
a Restricted-Use Appraisal.
The IAG was established to set the stan-
dards for property valuation, differentiat-
ing and clarifying the appropriate use of
individual assessment methods in deter-
mining estimated property value, and fur-
ther defining Evaluations as an
approved alternative. Appraisals, which
are time consuming and cost intensive,
are not always necessary; and BPOs and
AVMs, without additional information, do
not meet the new guideline requirements
for certain federally-related transactions.
The new product from CoreLogic offers an
alternative that saves lenders time and
money by leveraging the vast proprietary
data available from CoreLogic to enhance
and clarify its results.
We developed the Residential
Evaluation Report in direct response to
requests from lenders and servicers for
a solution to help them meet the new
standards set by the interagency guide-
lines, said Kevin Wall, senior vice pres-
ident of CoreLogic Default Services.
Evaluations are not new, but the
guidelines have now officially estab-
lished this option as a step to bridge the
gap between BPOs and appraisals.
Utilizing the vast CoreLogic property
database allows us to offer a data-
enhanced valuation tool that few can
match.
Zillow Launches
New Android App
Zillow has announced the
launch of its free Zillow
Mortgage Marketplace
Android App giving home
shoppers on-the-go access
to the loan shopping
experience of the Zillow Mortgage
Marketplace. Also available for the
iPhone, the Zillow Mortgage Marketplace
provides personalized loan quotes, lender
ratings, real-time rates and mortgage cal-
culators all in one place.
Since we brought Zillow Mortgage
Marketplace to mobile in June 2011, the
Zillow Mortgage Marketplace app finan-
cial calculators have been used more
than 1.5 million times, proving people
want access to mortgage and financing
information when they are out looking at
homes, said Erin Lantz, director of Zillow
Mortgage Marketplace. With the Android
app, we were able to take advantage of
the unique menu functionality that
enables users to easily share information,
such as mortgage rates and loan quotes,
from every page.
The Zillow Mortgage Marketplace
Android App gives home shoppers
access to: A payment calculator that
helps consumers estimate what their
monthly payment will look like for a
particular home; an affordability calcu-
lator that helps shoppers narrow their
home search to homes within a specific
price range, based on income, down-
payment and monthly debt informa-
tion; a refinance calculator that allows
consumers to compare their current
loan and new loan quote to estimate
potential savings if they refinance; a
mortgage shopping experience that
enables users to request and receive
personalized loan quotes, read lender
reviews and connect with a lender;
SPONSORED EDITORIAL
continued on page 39
By Raymond Bartreau
Once you have exhausted all of your past clients, contacts and referral
partners with the new Home Affordable Refinance Program (HARP) prod-
uct, whats next? You will want to start thinking about other forms of
generating new business in the marketplace with this program. There are
more than 27 million Fannie Mae and Freddie Mac loan holders nation-
wide who have no idea about HARP 2.0. The goal here is to find your
audience within this large group and get yourself in front of them, or bet-
ter yet, get them to come to you. The best way to do this is direct mar-
keting, which consists of a few different options and avenues: Radio, TV,
cold calling, direct mail and the Internet.
As we all know in the mortgage industry, lenders have guidelines on
pretty much every loan product on the market. If you are going to use
direct marketing in the mortgage industry, the first thing you want to do
is find the amount of homeowners that fit within your lending capabili-
ties, in this case, we are talking about HARP 2.0. Some recent count stud-
ies were ran with three of the industrys leading database compiler/man-
agers of mortgage and here is what we came up with:
I There are more than 27.5 million Fannie Mae and Freddie Mac loans
in America right now.
I There are currently more than 11 million Fannie Mae and Freddie Mac
homeowners that are upside down on their mortgage (more than 100
percent LTV).
I Two states have more than 1.8 million, four states have more than
475,000, and another 31 states have 45,000-plus homeowners who
can be helped.
I Of those 11 million, nearly 60 percent of these homeowners are cur-
rent right now on their mortgage.
I The other 40 percent-plus could get current and potentially be helped
before the end of 2013 if they are educated soon and make the efforts
for the next six to 12 months.
Depending on your specific lender requirements for this program, you
would take these massive databases, and filter them down based upon
the criteria you are looking to lend to. FICO, LTV, loan amount, origina-
tion date, late(s), no bankruptcies, and many more filters are available
when you are looking to create your perfect audience.
After extreme HARP 2.0 overlay filtering, we end up with a total of 2.3
million marketable (outbound with addresses) homeowners who may
qualify for HARP 2.0. Of those, more than 215,000 homeowners are avail-
able to be called after we do a Do-Not-Call (DNC) scrub on the database.
Since most of these folks have not seen a mortgage offer over the last two
to four years, you should see a pretty good response on any direct mail
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sharing functionality that allows shop-
pers to share current mortgage rates,
calculator results and loans requests via
e-mail, Twitter or text message; and
Zillow Mortgage Marketplace apps are
available for download for free in the
Android Marketplace and iTunes App
Store.
Nationwide Appraisal
& Settlement Network
Introduces PanelPlus
Vendor Management
Solution
Nationwide Apprais-
al & Set t l ement
Network (NASN) has
announced the launch of its PanelPlus
service. PanelPlus allows clients to main-
tain their existing relationships by let-
ting NASN take over approving, manag-
ing and maintaining their preferred
vendor profiles in a compliant manner.
The PanelPlus service can work in two
different ways. Clients can choose from
either a customized version of this serv-
ice or select the standard service. The
customized options allow the client to
create their appraiser panels in a com-
pliant manner by having NASN manage
the panel with respect to Appraiser
Independence guidelines.
In cases where the client prefers to
customize this feature, NASN will regis-
ter and approve appraisers for addition
to the panel, manage and track per-
formance, and report back to the client,
quarterly, with results. Performance
management and tracking is provided
so clients are able to maintain stan-
dards and reach new goals with regards
to quality and efficiency.
Should a less hands on approach be
desired, NASNs network of appraisers
will be utilized. This is the PanelPlus
standard option. NASNs team of
account managers work with the
appraisers building a solid rapport and
maintaining a successful working rela-
tionship with each of them. They coach
their appraisers on performance, com-
munication and quality by staying in
tune with their files and their clients
individual needs.
Fannie Mae Announces
Expansion of Its Online
Offers System
Fannie Mae has announced the expan-
sion of its Online Offers system to col-
lect and manage real estate purchase
offers for Fannie Mae-owned properties
across the country. Real estate profes-
sionals will now submit offers online on
behalf of clients, receive receipt confir-
mation and track the status of submitted
offers through the HomePath.com Web
site. Fannie Mae launched the Online
Offers pilot in November 2010 in
Orlando, Fla.; San Diego, Calif.; and in
Wayne County, Detroit, Mich. to develop
the platform and make any necessary
improvements. The Online Offers feature
is now available for all properties on
HomePath.com across the nation.
Collecting offers online through
HomePath.com will provide greater
transparency for homebuyers and their
agents, said Jay Ryan, vice president of
real estate-owned (REO) properties at
Fannie Mae. Our online platform will
make it easier to sell properties to owner
occupants, which is a major factor in
helping to stabilize communities across
the nation.
George Philbeck, a real estate profes-
sional with Keller Williams Advantage II
Realty in Orlando, Fla., has been using
Online Offers since the pilot launched in
2010.
As an agent, I believe Online Offers is
efficient, informative and user-friendly,
said Philbeck. With Online Offers, my
clients offers are guaranteed to make it
to the right person at Fannie Mae for
review. It has worked very well for me
and for my clients.
HomePath homes are owned by Fannie
Mae and include a wide selection of prop-
erties, including single-family homes, con-
dominiums, and town houses.
QuestSoft Adds
Geocoding Auditing and
Lending Analysis to
HMDA RELIEF
QuestSoft has announced an upgrade to
its HMDA RELIEF software in prepara-
tion for the 2011 submissions. The
upgrade implements new geocoding
tools, including integrated support for
both 2000 and 2010 Census tracts and
adds additional quality control (QC)
audits to prepare for regulatory exams.
The primary benefit to lenders using the
upgraded HMDA RELIEF is higher quali-
ty data scrubbing tools and more effi-
cient tools for analyzing the file.
Lenders must do more with their
HMDA data than just submit an annual
report, said Leonard Ryan, founder and
president of QuestSoft. HMDA RELIEF has
been enhanced to provide the additional
analysis needed to interpret the data,
identify potential errors and better pre-
pare for regulatory exams.
Ryan also said the addition of regula-
tions, such as the Nationwide Mortgage
Licensing System (NMLS) quarterly call
reports, means that lenders are
required to use HMDA-related data
year-round.
Ryan said HMDA RELIEF has also
introduced new and upgraded LOS
interfaces, bringing the total number of
integrations to the industrys top loan
origination systems to 42. New inter-
faces include FIS FLO and ISGNs
Catapult, along with enhancements to
fair lending data imports for BytePro
and Ellie Mae Encompass.
HMDA RELIEF offers lenders a com-
pliance solution with enhanced features
to accurately prepare and submit HMDA
data. Features include summary per-
formance reports and rate spread
analysis reports by race, ethnicity and
gender. Fair lending fields are also col-
lected and available for analysis, espe-
continued on page 30
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heard on the street continued from page 11
an account executive for the
Maryland territory for Interbank
Mortgage Company.
I Mortgage Returns has named Jim Blatt
as its new chief executive officer.
I Paul Chevez has been named direc-
tor of finance for Bay Equity Home
Loans.
I LenderLive Network has named
Patrice Power as its new senior vice
president of marketing.
I StreetLinks Lender Solutions has
added a number of new additions,
including: Shane Martin as vice pres-
ident of national sales, Tony Gioia as
vice president of external sales, Mark
Tague as AVP of national sales for
LenderX, Joel Munn as AVP of nation-
al sales, and Geoffrey Helmen as
national account manager.
I Kevin Wall has been named senior
vice president of the default services
division for CoreLogic.
I Ryan P. Menery has joined the
wholesale lending team as an
account executive for ReverseIt!
I The Mortgage Bankers Association
(MBA) has announced the following
five individuals have received their
Commercial Certified Mortgage
Banker (CMB) designation: Thomas
Bernaciak of First Housing
Development, Cristofer Brown of
Summit Investment Advisors,
Thomas Cooley of CB Richard Ellis,
Bradley Joyner of Mississippi Home
Corporation, and Jay Pittard of
EaseCap Holdings Inc.
I HomeStreet Bank has announced the
addition of several former MetLife
Home Loans team members, includ-
ing Rose Marie David, Anthony
Grasst, Natalie Overturf and Jeff
Schaller.
I PrimeLending has announced the
addition of Karyn Wilson as senior
vice president, regional manager of
the mid-Atlantic region.
I Inlanta Mortgage has added Branch
Manager Mark Schulenberg to its
Oak Brook, Ill. office.
I Greenlight Financial Services has
named Michael Petree as president
of its consumer direct mortgage plat-
form.
Your turn
National Mortgage Professional
Magazine invites its readers to submit
any information, events, passages, pro-
motions, personal or professional
occurrences that seem appropriate
and/or other pertinent data to the
attention of:
Heard on the
Street/Mortgage
Professionals to Watch
column
Phone #: (516) 409-5555
E-mail:
newsroom@nmpmediacorp.com
Note: Submissions sent via e-mail are
preferred. The deadline for submis-
sions is the 1st of the month prior to
the target issue.
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new to market continued from page 29
cially important with the Dodd-Frank
legislation looming. QuestSofts HMDA
RELIEF managed the submission of
roughly 25 percent of all funded appli-
cations in 2010.
QuestSoft also offers Compliance
EAGLE, an automated compliance
review tool that helps financial institu-
tions evaluate loan files for adherence
to the full range of mortgage lending
regulations, including Real Estate
Settlement Procedures Act (RESPA),
HMDA, Truth-in-Lending Act (TILA),
Community Reinvestment Act (CRA),
flood determination requirements and
other consumer and predatory lending
laws. The company also offers CRA
RELIEF, which provides banks and other
lenders specific tools designed to ease
the collection, analysis and reporting of
CRA data.
New CoreLogic Tool to
Assist Servicers Adapt to
Default Process Changes
CoreLogic has released
a new default servicing
platform to the mort-
gage industry that will
streamline the way
mortgage servicers manage loans
through all stages of the default lifecycle.
The new platform, named DefaultView,
opens pathways between previously dis-
connected servicing functions, allowing a
dynamic exchange of information across
multiple departments. The platform
offers nine modules that interconnect
within its architecture to help provide a
more efficient and transparent default
servicing operation.
DefaultView uses a master-loan
architecture that offers a singular view
of a loan. This design enables end users
across a default enterprise to easily see
a complete transaction history includ-
ing workflow steps, resulting data, out-
comes and all related documents and
messages. By enabling top-down trans-
parency across all relevant default
departments and functions, the plat-
form simplifies reporting and strength-
ens management oversight.
DefaultView is one of the most
transparent and cohesive solutions for
managing default, said Kevin Wall,
senior vice president of default services
for CoreLogic. This platform is unique
in that it uses a unified approach to
give servicers an unprecedented level
of visibility into the path of a loan in
default from beginning to end. All mod-
ules can be used together as an end-to-
end solution, or in configurable combi-
nations suited to specific needs.
Built on an open-architecture foun-
dation, this fully integrated, web-based
platform brings together servicing data
and functions to unify default servicing
efforts. From loan modification deci-
sioning through claims processing,
DefaultView provides a single user
interface (UI) accessed through a
secure, role-based logon to the plat-
form portal. Users with role-specific
permissions can transition between
functional modules without ever leav-
ing the platform. DefaultView also pro-
vides the ability to track specific histor-
ical activity throughout the loan default
lifecycle, from creation to conclusion.
The beauty of DefaultView is that
servicers can define their workflow and
business rules, said Chris Howard, vice
president of technology solutions for
CoreLogic. The platform can be adapt-
ed to integrate a servicers existing tech-
nology, so theres no need for expensive
programmers to rewrite code or man-
age configurability. This product will be
key to remaining nimble in a very
dynamic default market.
Seamless integration coupled with
the comprehensive scope of the plat-
form will allow servicing businesses to
address a wide spectrum of concerns.
DefaultView will not only shrink
bottom-line costs by boosting accuracy
and efficiency, but also improve short-
and long-term operations for servicers
of all sizes and with all loan volume lev-
els, which will ultimately support the
health of the servicing industry as a
whole, said Howard.
ServiceLink Releases HOA
Management Solution
ServiceLink has
announced the
availability of HOA
Resolve, its proprietary system dedicated
to homeowners association (HOA) manage-
ment. ServiceLink has years of proven, ded-
icated experience in HOA management
and that level of knowledge and first-hand
experience is reflected in HOA Resolve.
HOA Resolve prevents closing delays and
mitigates lenders and servicers risk of
overpayment by quickly identifying HOAs
through direct access to information from
Fidelity National Financials network of
more than 5,000 local title agents and
working with them to bring any outstand-
ing fees current. This is accomplished
through ServiceLinks review of existing
mortgage or title documents and verifica-
tion against an internal database, as well as
other drivers. ServiceLink then contacts
the HOA regarding the status of the
account to confirm all charges are within
legally required limits and, if possible,
negotiates the terms to reduce its clients
financial exposure. Once finalized,
ServiceLink handles payments and pro-
cessing to ensure there are no outstand-
ing HOA title curative issues when the
property goes under contract.
The issue of HOA fees is a significant one
for lenders in todays market. When a
financial institution takes possession of a
property through foreclosure or through a
bulk sale, for example, it may also assume
the responsibility for any outstanding HOA
fees or penalties tied to that property.
ServiceLinks HOA Resolve helps lenders by
coordinating all open accounts associated
with a foreclosure and ensuring that they
are closed upon finalization of the transac-
tion. In doing so, ServiceLink is saving its
lender customers, on average, more than
$3,100 per foreclosure.
Lenders understand and expect to ful-
fill HOA obligations tied to their portfolio
properties and in working closely with
HOAs and their attorneys, we help ensure
that those obligations are met and that the
fees and dues are not above and beyond
what is supported by the legal statute,
said Stacey Bayley, senior vice president of
asset management and disposition for
ServiceLink. Through HOA Resolve, our
lender customers are better positioned to
quickly identify properties with HOA com-
mitments and determine the correct set-
tlement amount prior to closing.
Real Property Decisions
Releases Tool for
Improved Diligence
on Non-Performing
and REO Assets
Real Property Decisions has released its
new Default Reconciliation Report, a valu-
ation analysis service which provides mort-
gage servicers and investors with critical
valuation information to supplement a
broker price opinion (BPO) or appraisal.
The Default Reconciliation Report meets
the growing industry demands for a higher
level of valuation diligence for non-per-
forming and real estate-owned (REO) assets.
continued on page 32
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By BJ Bounds
Do you know what
you want in your
loan origination sys-
tem (LOS)? If youve
been in the industry
for awhile, you have
a pretty good idea, and you may have
spent months finding just the right sys-
tem for your company. Perhaps,
though, there is a slight nagging con-
cern that your system may not be as
efficient as it could be, or as easy to use
as youd like it to be, or even able to fit
your needs as they change.
Do you lie awake at night wishing
you could take a quick peek into your
pipeline? Is your LOS time-intensive or
complicated to learn and use? Would
you like the peace of mind knowing
that only certain employees of your
choosing can make changes to loan
data? Can you make sense of the files in
your system? Would you like to? If these
questions sound familiar to you, you
are not alone. Features such as ease-of-
use, security, accessibility, organiza-
tion, and accountability are extremely
important to organizations that origi-
nate and process mortgage loans.
Delivery and accessibility
But its not always the feature, its how it
gets to you that often matters more. Its a
matter of deliverables versus delivery.
We are a very Web-focused culture now
and so many of the things we do are on
the Internet: Social media, e-mail, search-
es, marketing and games. The beauty of
the Web for the mortgage businesses is
that it allows professionals to be connect-
ed to their pipeline 24/7, wherever there
is a secure Internet connection.
For the mobile mortgage professional,
having access to your LOS remotely is
vastly convenient. Even for small offices,
having the ability to stay on top of your
business gives you greater flexibility with
your time. You no longer have to be teth-
ered to your office computer to give your
clients the attention they deserve. But
beyond convenience and flexibility, set-
ting up your LOS in this way also gives you
greater security over your sensitive data.
In order to accommodate remote
Internet access to your LOS system, all of
your data is stored on a centralized serv-
er. This server system means that your
files are all stored in one secured loca-
tion. You no longer have to worry about
your computer crashing with all your data
or your laptop being stolen with your
clients sensitive data along with it.
Additionally, if you or somebody else in
your office works on a file offline, it is
automatically uploaded to the server the
next time it connects, making sure the file
in the server is the only file for that
clientclearing the way for instant and
easy oversight.
Un-complicate
your business
Utilizing advanced technology designed
to help you become more efficient and
productive doesnt mean your life has to
become more complicated. If you are try-
ing to go paperless, or at least reduce the
amount of paper and clutter in your
office, why would you want to deal with
cluttered technology?
If your system is complicated to use
and your learning curve is longer than
you would prefer, its probably not going
to be the best tool for your business.
Technology is supposed to make your life
simpler, not scare you with its obscurity.
Theres nothing wrong with being
advanced on the inside, but simple to use
on the outside.
Its a concept that Microsoft doesnt
always get right when they put out a new
version of the programs we use every day.
Remember having to learn Office prod-
ucts all over again when 2007 came out?
To be the right tool for you, your system
needs to have the features and function-
ality you need without the complexity
you dont.
Make it your way
It also wouldnt be an effective tool for
your business if it didnt work the way
you wanted it to. We often depend on
technology that dictates to us how we
should run our processes, and inevitably,
our businesses. To adequately support
mortgage professionals, your systems
need the flexibility to change as your
needs change. Your compliance require-
ments change constantly. You need to be
able to enforce certain behaviors of your
end users through your technology.
The ability to create your own rules in-
house, either action-based or
field/screen level, is important. But
again, if the process is too complicated or
requires a special team of IT experts to
develop the rules you need, its not going
to be an effective tool for you in your
quest for efficiency and profitability.
When we talk about configurability,
we must include a significant integration
with flexibility. To be able to configure
your own system with rules and process
stops is to have the flexibility to work the
way you want to. Your software should
have the flexibility to conform to your
way of doing business, not the other way
around. Configurability comes into play
when the flexibility you need is managed
by you, not your technology vendor.
Securing accountability
To enforce the behaviors that your busi-
ness needs for compliance and efficiency,
you must have rules and the technology
to implement them. Restricting access is
the first step in securing your business
and ensuring process accountability.
If your LOS isnt providing the sim-
plest access restrictions, your business
is vulnerable to security leaks, lost sen-
sitive data, or inadvertent data manip-
ulation. You need to be able to deter-
mine who in your business has access to
certain fields, screens or files. And you
need to be able to change restriction levels
at any time.
Dreaming
of an
LOS
continued on page 33
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This innovative new valuation analysis
service is powered by a unique combination
of geographically optimized third party data
and desktop appraiser expertise, said Eric
Taylor, president of Real Property Decisions.
It delivers an accurate and defensible
means for residential property servicers and
investors to make better acquisition, pric-
ing, and disposition decisions.
Desktop value reconciliation services
are performed against two client-supplied
baseline property valuations, which may
include any combination of listing BPO,
independent BPO, or real estate
appraisals. Two additional automated
data sets are also incorporated into the
analysis and reconciled accordingly. They
include a cascading Intelligent Valuation
Report and an advanced property rental
report from RentRange. These key addi-
tions deliver a wealth of new knowledge to
the appraiser and the end user, effectively
bridging the information gap present in
traditional valuation products.
The Default Reconciliation Report is a
Uniform Standards of Professional
Appraisal Practice (USPAP)-compliant
product that supports retrospective and
complex reconciliation requests, and can
be easily modified to incorporate addi-
tional data and analytics into the decision-
ing process.
Genworth Streamlines MI
Site to Speed Up Loan
Submission Process
The U.S. Mortgage Insur-
ance (USMI) unit of
Genworth Financial Inc.
has announced enhance-
ments to its customer-fac-
ing Web site that will reduce the data
required to submit a loan and give cus-
tomers a single Web portal to deliver all
loans submitted to Genworth for mortgage
insurance (MI) coverage. The enhance-
ments also allow customers to submit con-
tract underwriting and Home Affordable
Refinance Program (HARP) loan submis-
sions through the same Web portal, using
a single user name and password.
We know our customers prefer going
to one Web site for all their loan submis-
sions, said Neale DRozario, chief infor-
mation officer for Genworths USMI unit.
These enhancements are part of the com-
panys efforts to continually improve and
make it easy for customers to do business
with us.
In addition to providing a single portal
for customers to submit all their loans to
Genworth, the enhancements give cus-
tomers the ability to perform one-step
document uploads, and to view and track
their loan status.
Quandis Integrates Military
Search Service With Case
Management System
Quandis Inc. has announced that it has
integrated its military search service with
KMC Information Systems LCs (KMCIS)
CaseAware solution that is utilized by law
firms and trustees in default servicing. The
new integration is seamless and allows
users to quickly initiate searches from
within KMCIS CaseAware application to
identify borrowers in default that are
active military personnel, helping adhere
to the Servicemembers Civil Relief Act
(SCRA) of 2003. The SCRA requires that ser-
vicers and foreclosure attorneys follow
certain processes before foreclosing on an
individual who has active status in the
United States military.
Our integration with CaseAware adds
an efficient check and balance to the fore-
closure process workflow, said Scott
Stoddard, chief executive officer of
Quandis. There are a number of moving
parts and parties involved in the proper
completion of a foreclosure; making sure
servicers and law firms comply with the
SCRA is critical. In recent months, compa-
nies have been hit with steep fines for
incorrectly foreclosing on active military
personnel. By and large, companies fail to
comply with the SCRA because most
searches are performed manually on the
Department of Defenses Web site, which
is tedious, time consuming and prone to
exposure.
With the click of a button, CaseAware
users can initiate an automated status
search directly from within their existing
workflow that instantly returns accurate
results along with event triggers that
determine the next task. Quandis imports
detailed reporting on all searches back
into CaseAware that time and date stamps
the official status report provided on the
Department of Defenses Web site.
We have been told by the many
industry law firms we serve that not
complying with the Servicemembers
Civil Relief Act sets the stage for lawsuits
and the potential to rescind foreclosure
transactions, said Dan Cannon, COO at
KMCIS. When searches are done manu-
ally by processors, an element of risk is
introduced due to the potential for user
errors. With our new interface to
Quandis military search service, howev-
er, KMCIS clients now have the ability to
process their Department of Defense
searches in an automated fashion,
thereby reducing the time and effort to
complete searches and the potential for
inaccuracies. An integration with
Quandis simply made a lot of business
sense to deliver these efficiencies to our
customer base.
Combined, the integration between
Quandis and KMCIS bridges the risk gap of
improperly foreclosing on borrowers in
default who are active military service
members and are thus protected from
foreclosure by the SCRA. In addition to law
firms, servicers and banks can also utilize
Quandis military search service to per-
form automated bulk searches on loan
portfolios. Clients can use the service as a
standalone solution or as integrated with
their existing servicing platform.
GSF Mortgage to Offer
Credit Repair Assistance to
Vets Seeking VA Loans
GSF Mortgage Chief
Operating Officer Chad
J ampedr o has
announced that GSF
Mortgage is offering to pay for credit repair
services for any veteran who would be eli-
gible for a U.S. Department of Veterans
Affairs (VA) Guaranteed Home Loan. In
todays tumultuous economic climate,
consumer credit has taken a hard hit,
Jampedro said. There are many military
veterans who are already suffering finan-
cially so we wanted to do something that
could help give them a fresh start. Credit
repair services are designed to do just that
by helping to remove negative credit infor-
mation and improve their credit score.
VA guaranteed loans are made by pri-
vate lenders, such as savings and loans,
banks or mortgage companies to eligible
veterans for a home purchasewhich
must be for their own personal occupancy.
Veterans can apply for a certificate of eligi-
bility by submitting a completed VA Form
26-1880, request for a certificate of eligibil-
ity, along with proof of military service.
Not only can veterans leverage the
benefits of a VA home loan, but now they
can also take advantage of this valued serv-
ice through our company, said Jampedro.
Nations Lending Services
Launches New Site
Nations Lending Services
has announced the
launch of its new Web
site with innovative
functionality and brand new tools. The
new site launch includes new user tools
such as an online HUD editor, a Good Faith
Estimate (GFE) calculator, and a rate esti-
mator for homeowners.
We have a large variety of customized
technology solutions for clients that have
been developed internally over 20 years,
said Kelly Kern, president of Nations
Lending Services. Known as a leader within
the real estate information industry by most
major national real estate technology firms,
we have had many long time working part-
nerships with companies like Encompass,
RealEC, OTX, FNN, Calyx, EPass, and more.
Our initial Web site rollout 12 years ago was
cutting-edge. Over the past decade, several
competitors have copied our online solu-
tions. We feel that our new initiatives will
again revolutionize the industry and that
they will be the benchmark all industry
providers will use for years to come.
Nations new Good Faith Estimate
Calculator will allow customers to obtain a
quote in a matter of seconds for no charge.
The information provided, including taxes,
closing fees and recording fees, is guaran-
teed. The Rate Estimator will provide home-
owners with an estimate on their basic title,
closing and property search rates in a fast,
easy-to-use, and free manner.
Of the new features, there is also an
online HUD editor, that will allow Nations
Lendings clients to gain free access to edit
bank and lender fees, expedite approvals
with the click of a button, and to download
a copy of the final HUD instantly. This func-
tion also removes the need for e-mail, as
the site is now a one-stop source for pro-
ducing, editing and approving a HUD-1.
Vantage Media
Launches Mortgage Rate
Pay-Per-Click Listing
Product for Lenders
Vantage Media has
announced t he
launch of Mortgage
Rate Listings, an addition to its BrokersWeb
premium pay-per-click (PPC) marketing net-
work for insurance and financial services.
The Mortgage Rate Listing is a premium cost-
per-click (CPC) advertising unit for mortgage
lenders and brokers marketing to new cus-
tomers. Mortgage Rate Listings build upon
the companys existing BrokersWeb text-
based CPC advertising platform to create a
vertical-specific ad unit that integrates
lenders respective rate details alongside
text-based advertising. This new offering is
the first of the enhanced customer acquisi-
tion solutions planned to further accelerate
the vertical expansion and products that
BrokersWeb and Vantage Media developed
separately prior to their 2011 merger.
For advertisers, the BrokersWeb plat-
form features an auction-based market-
place where lenders can bid based on loan
type (purchase or refinance), loan principle
categories, and geographies. The
BrokersWeb platform offers back-end tools
and reporting to track conversions from
click-to-loan request, and ultimately to
funded loan. Advertisers are charged when
a prospective borrower clicks on its respec-
tive Mortgage Rate Listing, signifying a spe-
cific interest in the advertisers published
rate(s) and messaging.
For Web publishers, Mortgage Rate
Listings will also be a premium revenue
vehicle for targeted mortgage website pub-
lishers capable of delivering high-quality
clicks to Vantage Media advertisers. Vantage
Media is launching Mortgage Rate Listings
with placements on ultra-targeted publisher
websites such as Top10MortgageRates.com,
Loans.org and MortgageCalculator.com
Web sites.
This new product allows us to demon-
strate to a new category of marketers our
commitment to delivering our advertisers
the right product, exceptional service and
top-notch results, said Michael Foster, vice
president of Vantage Media. We look for-
ward to offering to our mortgage advertis-
ers this expanded platform and the same
expertise in traffic acquisition and dedica-
tion to advertisers online conversion goals
that is behind our success in the insurance,
education and home verticals.
Your turn
National Mortgage Professional Magazine
invites you to submit any information pro-
moting new niche loan programs, new
products or any other announcement
related to the introduction of a new pro-
gram, to the attention of:
New to Market column
Phone #: (516) 409-5555
E-mail: newsroom@nmpmediacorp.com
Note: Submissions sent via e-mail are pre-
ferred. The deadline for submissions is the
1st of the month prior to the target issue.
new to market continued from page 30
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For those who have the access required
for their role in the process, ensuring that
they follow your rules while working with
client files is extremely important for com-
pliance and pipeline control. This is where
the importance of configurability comes
in. The rules you create will dictate the
appropriate course of action for each step
in the process and for each role in your
company. These rules govern both compli-
ance and effective workflow and give you
the gift of accountability throughout your
organization.
Organization
The visibility into your pipeline you get
from having a server-based system gives
you the benefit of oversight and manage-
ment of your processes. But its not just
about having a centralized file location or
visibility into your workflow, its also
important that you have the ability to
package your loan documents in any num-
ber of orders to accommodate the needs
of your lenders and vendors. By also hav-
ing the ability to drop in documents from
your desktop or e-mail, your processes run
smoother and organizing your workflow is
a breeze.
Another important aspect of organizing
your loan pipeline is simplifying and
automating your document and services
ordering. With often hundreds of available
vendors to choose from, ordering directly
from your LOS saves time and effort as
there is no re-keying of data that could
result in errors and time-consuming
returns.
End the nightmare
At the end of every rainbow is a pot of gold,
and at the end of every dream is an awak-
ening. If youve ever wondered if you can
achieve a higher level of productivity with-
out spending countless hours learning new
software and reading convoluted manuals,
now is your chance to wake up and explore
your options.
Your technology does not have to keep
you up at night. Its meant to enhance your
business, not create additional stress and
worry. An LOS can be extremely diverse in
delivery method and functionality. When
you find reliable delivery, flexibility and
robust security packaged in an easy-to-use
and easy-to-manage platform, youve
found the LOS youve been dreaming of.
B.J. Bounds is senior marketing communica-
tions specialist for Calyx Software. In addi-
tion to media relations and copywriting, BJ
is a contributing author to the Calyx
Software blog, CalyxCorner. She has more
than 10 years of experience in sales and cor-
porate marketing with a focus on technolo-
gy that spans several industries. She may be
reached by phone at (800) 362-2599 or visit
www.calyxsoftware.com.
dreaming of an los continued from page 31 nmp news flash continued from page 25
Since the post-bubble drop in home
prices eased in January of 2009, weve gen-
erally seen that prices for homes in the
lowest 20 percent of local markets in the
metropolitan areas covered by the LPS HPI
now differ by more than the highest 20
percent from their levels 10 years ago,
said Kyle Lundstedt, managing director of
LPS Applied Analytics. In those metropol-
itan areas where lowest-priced homes
have increased in value, the differences
between the high and low ends of the
market have usually shrunk; where they
have decreased in value, the differences
have grown.
The LPS HPI national average home
price for transactions during November
2011 was $199,000a decline of 0.6 per-
cent during the month relative to October
2011, reaching a price level not seen since
October 2002 (see chart below). This is the
fifth consecutive month of price decreases.
The partial data available for December
suggests further price declines of approxi-
mately 0.8 percent.
LPS reported partial data from
November transactions in its December
release, which proved a reasonable indica-
tor for Novembers performance showing a
preliminary 0.5 percent estimated decline,
compared to the 0.6 percent for the full
months data.
LPS HPI average national home prices
continue the downward trend begun after
the market peak in June 2006, when the
total value of U.S. housing inventory cov-
ered by the LPS HPI stood at $10.8 trillion.
Since that peak, the value has declined
30.6 percent to $7.5 trillion. During the
period of most rapid price declines, from
June 2007 through December 2008, the
LPS HPI national average home price
dropped $56,000 from $282,000, which
corresponds to an average annual decline
of 13.8 percent.
Since December 2008, prices have
fallen more slowly, interrupted by brief
seasonal intervals of rising prices.
During this period of more slowly
declining prices, the national average
home price has fallen approximately
$26,000 from $226,000.
Twenty of the MSAs with average
price increases were in Florida, with the
remainder in Arizona, Tennessee and
New York. Phoenix was the best-per-
forming MSA, as it was in October, with
an increase during November of 1.1
percent. The other four of the top five
MSAs with increases (greater than 0.6
percent) were in Fort Lauderdale,
Miami and Orlando, Fla. and in Lake
Havasu City-Kingman, Ariz.
The five MSAs with the greatest
declines in November were all in
Georgia. Columbus, Macon, Gainesville
and Augusta (in addition to Atlanta)
declined more than two percent. MSAs
that declined more than 1.5 percent
were on the Middle Coast, in Chicago;
Lake County, Ill.; and Kenosha County,
Wis. One hundred and five MSAs
declined more than one percent.
Property Valuation Fraud
Risk Sees Eight Percent
Quarterly Jump
Interthinx has released its
quarterly Mortgage Fraud
Risk Report covering data
collected in the fourth
quarter of 2011. According
to the most recent analysis,
certain regions of the New York Tri-State
area have moved into the very high risk
category, due primarily to the increase
in property valuation fraud risk.
For the purposes of the report, the New
York Tri-State area is defined as the New
York City metro along with the Connecticut
metros of Bridgeport and New Haven and
the New Jersey metros of Atlantic City and
Ocean City. Across the United States, the
Property Valuation Fraud Risk Index
increased nearly eight percent in Q4 of
2011 over the previous quarter. The rise
follows a period of decline and stability in
valuation-related fraud.
Other results uncovered in the most
recent Interthinx Mortgage Fraud Risk
Report include:
I The national Mortgage Fraud Risk Index
was up 1.4 percent over the last quarter
and 3.6 percent from a year ago to 145.
Overall, the index has remained at the
upper end of the narrow band (140-145)
over the last seven quarters.
I Although Income/Employment Fraud
Risk is only up one percent since Q3 of
2011, the index has jumped nearly 14
percent since a year ago and 46 percent
over two years ago, putting lenders at
high risk for this type of fraud.
I With an index value of 247, Arizona
overtook Nevada (with an index value of
242) as the nations Riskiest State.
Nevada had held the top spot since the
first quarter of 2010. Florida is the third
riskiest state for mortgage fraud and is
home to ZIP code 33993, currently the
riskiest ZIP code in the nation.
Valuation fraud continues to be a
problem for lenders intent on mitigating
overall fraud risk, said Mark Chapin, chief
valuation officer for Interthinx. Lenders
must take great care with their collateral
valuation process in this environment, as
many areas around the country are still
experiencing home value declines.
Technologylinked with the honed skills
of qualified appraisersproduces the
most credible results in our constantly
moving marketplace.
DocMagic Teams With
U.S. Army to Distribute
Sergeant Doc Bunny
DocMagic Inc. has an-
nounced that it has
teamed with the 315th
U.S. Army Tactical Comp-
any to distribute this
years new DocMagic
Bunny Sergeant Doc to local children
and their families. The bunny is dressed
continued on page 35
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By Frank Tibbs
T
he most severe economic reces-
sion since The Great Depression
has dramatically impacted all
sectors of the financial markets. The
effect on the mortgage market and on
loan servicers specifically, forced a
paradigm shift in the business model. Large volumes of
non-performing loans, multiple and complex loan mod-
ification programs, increased scrutiny and regulation
and a heightened awareness by customers and the gen-
eral public are the new reality.
A thorough review and assessment of loan servicer
business operations is imperative and must address
compensation, staffing and training, data manage-
ment, compliance and reporting, default servicing
improvement, technology infrastructure and effective
application of software solutions.
Current state
Servicers are not the root cause of current problems,
but they are an important part of the solution. The
deluge of delinquencies and high volumes of foreclo-
sure were unanticipated and unforeseen conse-
quences of a housing bubble. Servicers werent
expecting it and their operating models werent
designed to handle it. The results are higher costs and
lower productivity over the last five years.
Loan servicing is essentially two distinct business
processes: Transactional and administrative.
I Transactional processes: Routine, standardized and
generally referred to as reporting and remittance.
I Have been readily automated and are scalable.
I Administrative processes: Collections, foreclosure pro-
cessing and real estate-owned (REO) disposition.
I Requiring decisioning and hands-on interaction.
I Have been more limited in automation and are
not easily scalable.
Since 2007, revenues are down and expenses are up.
The private label residential mortgage-backed securi-
ties (RMBS) market is essentially frozen. Hard costs are
up, delinquency rates are at four-to-five times historical
levels, fewer loans are being originated, loan balances
on the new loans tend to be lower, and demand for
specialty servicers is at an all-time high.
Servicing fees can range from 25 bps to 50 bps direct
servicing costs can range from 15 bps to 20 bps. Corporate
allocations add two to four bps. Higher rates of servicer
errors, Increased un-reimbursed foreclosure and REO
expenses, property inspection and preservation costs, and
advances due to higher delinquency rates and longer
foreclosure time lines put pressure on profitability.
Future state
Increased reliance on technology will require higher lev-
els of expenditure. Future state will include national serv-
icing standards, increased legal and legislative involve-
ment, and changes to servicer compensation. Investors
and rating agencies will stipulate more stringent require-
ments. Regulators will mandate compliance. Issuers and
guarantors will implement performance metrics and fees
and penalties for poor servicer performance.
Regulation will increase: Dodd-Frank and the
Consumer Financial Protection Board regulations,
Federal Housing Finance Agency (FHFA) Servicing
Alignment Initiative (SAI) and government-sponsored
enterprise (GSE)-revised servicer performance metrics
(STARS for FNMA and SSP for FHLMC). Changes include
specific performance measures and monetary penalties
for non-compliance, increased repurchase demands
and limiting or in some cases terminating servicers.
Business process assessment
Costs and efficiencies will be achieved through
refined and/or redesigned business processes.
Servicers will employ new technology to leverage per-
sonnel and increase productivity. An emphasis will be
placed on capability, capacity and cost. Individual
recommendations should be documented and a for-
mal implementation roadmap prepared and execut-
ed. An effective assessment supports recommenda-
tions to refine and redesign policies, processes and
procedures, effectively manage staffing needs,
enhance automation and leverage technology.
Servicers need to conduct a thorough business
process and technology assessment:
I Identify areas of improvement to existing process-
es and systems.
I Encompass all loan servicing functions.
I Include all internal and external service providers
and consumers.
I Technology assessments should include software,
hardware and personnel.
I Focus on current high-cost/high visibility issues for
performing and non-performing loans.
The business assessment process should constitute:
I Discovery: Reviews existing policies and procedures.
I Current state assessment: A holistic view of all
departments, systems and personnel.
I Risk assessment: Specific risks are identified relative
to each process,
I Gap analyses: Differences or deficiencies between
the desired state and current state.
I Recommendations and an implementation road map.
Frank Tibbs works in the mortgage and fixed-income
practice of Actualize Consulting. Most recently, Tibbs
served as project manager and business lead for the
Servicer Scorecard development and implementation of
the Servicing Success Program at Freddie Mac. He may
be reached by phone at (703) 489-6973 or e-mail
ftibbs@actualizeconsulting.com.
Loan Servicing:
Current and
Future Business
Process
Assessment
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in regulation military clothing as a trib-
ute to the men and women who serve
this country and the families that
eagerly wait for their return. Each year,
DocMagic delivers thousands of bun-
nies to its customers. The DocMagic
Bunny is a staple of the companys
brand and every year the employees at
DocMagic participate in a contest to
pick the theme. For 2012, the employ-
ees overwhelmingly chose to show sup-
port for our countrys troops by outfit-
ting Doc in regulation military fatigues
proudly displaying the American flag
and equipping him with a GPS device.
Sergeant Doc was specifically creat-
ed to honor the men and women who
serve in the armed forces, said
Dominic Iannitti. They and their fami-
lies make enormous sacrifices and we
wanted to show our appreciation. We
are pleased that the 315th U.S. Army
Tactical Company was able to help con-
nect us with the families of those who
serve. We are additionally gratified by
the enthusiastic response from our cus-
tomers, who have phoned and written
to thank us for honoring our nations
true heroes.
With the help of the 315th, Sergeant
Doc is being distributed to schools,
youth organizations, churches and
parks as well as the children and fami-
lies of those deployed. These contribu-
tions are in keeping with the finest mil-
itary traditions of the United States
Army, which greatly appreciates the
support of companies like DocMagic.
The campaign began during the holi-
day season and is now continuing into
the New Year.
Loan Mods Outpace
Foreclosure Sales
Nationwide as
1.05 Million Mods
Completed in 2011
HOPE NOW has
released its final
2011 loan modi-
fication data,
which shows
that an estimated 1.05 million home-
owners received permanent, affordable
loan modifications from mortgage ser-
vicers in 2011. The reported data for
December shows that, for the 2011 cal-
endar year, mortgage servicers com-
pleted approximately 695,000 propri-
etary loan modifications for homeown-
ers and 353,677 Home Affordable
Modification Program (HAMP) modifi-
cations as reported by the U.S.
Department of the Treasury. Over the
two year period since December 2009,
nearly three million permanent loan
modifications have been completed for
homeowners.
For the month of December, there
were approximately 80,000 loan modi-
fications completed, including 56,000
proprietary loan mods and 23,374 loan
mods completed under HAMP.
Additionally, the data show that loan
modifications outpaced foreclosure
sales for the fourth consecutive year. In
2011, there were approximately
843,000 foreclosure sales completed for
the year. This represented a significant
drop from the 1.07 million reported in
2010.
Since 2007, more than five million
permanent, sustainable solutions have
been offered and in the past two years,
almost three million have been done,
said Faith Schwartz, executive director
of HOPE NOW. While HOPE NOWs data
shows that total loan mods for 2011
were less than the number completed
last year, it is important to note that
foreclosure sales dropped by more than
21 percent from 2010.
Wells Fargo Ranks as Top
Commercial Servicer in
Volume in 2011
The Mortgage Bankers
Association (MBA) has
released its year-end
ranking of commercial
and multifamily mort-
gage servicers as of Dec. 31, 2011, and
at the top of the list of firms is Wells Fargo
with $437.7 billion in U.S. master and pri-
mary servicing, followed by PNC Real
Estate/Midland Loan Services with $355.1
billion, Berkadia Commercial Mortgage
LLC with $176.5 billion, Bank of America
Merrill Lynch with $115 billion, and
KeyBank Real Estate Capital with $108.2
billion. Wells Fargo, PNC/Midland,
Berkadia, Bank of America Merrill Lynch
and KeyBank are the largest master and
primary servicers of commercial/multi-
family loans in U.S. CMBS, CDO and other
ABS; PNC/Midland, MetLife, GEMSA Loan
Services LP, Prudential Asset Resources
and Northwestern Mutual are the largest
servicers for life companies; and
PNC/Midland, Wells Fargo, Deutsche Bank
Commercial Real Estate, Berkadia and
GEMSA Loan Services are the largest
Fannie Mae/Freddie Mac servicers.
PNC/Midland ranks as the top master
and primary servicer of commercial bank
and savings institution loans; GEMSA the
top credit company, pension fund, REIT,
and investment fund servicer;
PNC/Midland the top FHA and Ginnie Mae
servicer; Wells Fargo the top for loans held
in warehouse facilities; and PNC/Midland
the top for other investor type loans.
A primary servicer is generally
responsible for collecting loan pay-
ments from borrowers, performing
property inspections and other proper-
ty-related activities. A master servicer is
typically responsible for collecting cash
and data from primary servicers and
then providing that cash and data,
through trustees, to investors. Unless
otherwise noted, MBA tabulations that
combine different roles do not double-
count loans for which a single servicer
performs multiple roles.
MBA also asked firms to provide infor-
mation about loans on which they are the
named special servicerthat is, where the
firm stands ready to service the loan should
special problems develop, such as delin-
quency. The largest named special servicers
were LNR Partners, Inc., CWCapital LLC &
CWCapital Asset Management and C-III Asset
Management LLC.
The MBA survey also collected servicing
volumes for loans on commercial/multi-
family properties located outside the
United States. Hatfield Philips
International, an LNR Property Company
ranks as the largest master and primary
servicer of non-U.S. commercial/multifam-
ily mortgages, followed by Deutsche Bank,
PNC/Midland, Manulife Financial/John
Hancock and GEMSA.
Mortgage Delinquencies
Drop to 7.58 Percent in Q4
The delinquency rate for
mortgage loans on one- to
four-unit residential prop-
erties decreased to a sea-
sonally adjusted rate of
7.58 percent of all loans
outstanding as of the end of the fourth
quarter of 2011, a decrease of 41 basis
points from the third quarter of 2011, and
a decrease of 67 basis points from one year
ago, according to the Mortgage Bankers
Associations (MBA) National Delinquency
Survey. The non-seasonally adjusted delin-
quency rate decreased five basis points to
8.15 percent this quarter from 8.20 percent
last quarter.
The percentage of loans on which fore-
closure actions were started during the
fourth quarter was 0.99 percent, down
nine basis points from last quarter and
down 28 basis points from one year ago.
The delinquency rate includes loans that
are at least one payment past due but does
not include loans in the process of foreclo-
sure. The percentage of loans in the fore-
closure process at the end of the fourth
quarter was 4.38 percent, down five basis
points from the third quarter and 26 basis
points lower than one year ago. The seri-
ous delinquency rate, the percentage of
loans that are 90 days or more past due or
in the process of foreclosure, was 7.73 per-
cent, a decrease of 16 basis points from last
quarter, and a decrease of 87 basis points
from the fourth quarter of last year.
The combined percentage of loans in
foreclosure or at least one payment past
due was 12.63 percent on a non-seasonal-
ly adjusted basis, a 10 basis point decrease
from last quarter and was 107 basis points
lower than a year ago.
Mortgage performance continued to
improve in the fourth quarter, reflecting
the improvement we saw in the job mar-
ket and broader economy. The total delin-
quency rate and foreclosure starts rate
decreased and are back down to levels
from three years ago, said Jay Brinkmann,
MBAs chief economist and SVP of
research and education. A major rea-
son is that the loans that are seriously
delinquent are predominantly made up
of loans originated prior to 2008 and
nmp news flash continued from page 33
continued on page 38
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Getting the Word Out: Leveraging
Public Relations and Social Media
to Promote Your Expertise Locally
By Bob Zeitlinger
R
eferrals are the lifeblood of any
successful mortgage firm and
mortgage professional. Do right
by a homebuyer, illustrate expertise in
navigating the mortgage system, and
credibility is built with the client. Use
my guy, says the client to family,
friends and co-workers. He really
knows his stuff.
Sometimes, though, referrals are not
enough to keep the number of leads
coming in, especially in this economy. It
can be frustrating for hard-working and
conscientious mortgage professionals,
whose knowledge and expertise blows
away others in the industry, yet loses
business to these same less qualified
competitors.
More often, smart mortgage execu-
tives are leveraging the media and
social media in order to display their
knowledge and drive business. Some
call it public relations, media relations
or publicity. These folks are easy to
spot. They seem to be quoted in the
local paper discussing trends in mort-
gage applications or home-buying,
and/or the movement of interest rates.
If you Google Search their names, you
will probably see their mortgage-orient-
ed Facebook pages, Web sites, Twitter
accounts and/or blogs.
Any knowledgeable mortgage profes-
sional with a good sense of whats going
on in the local market can do it as
wellit just takes time, effort and a lit-
tle understanding of the process.
Remember, though, that it doesnt need
to be an all or nothing effort. Many
mortgage professionals are active in
social media, while others rely on tradi-
tional public relations to build their
brand and show off their expertise.
Public relations
Mortgage professionals expend a great
deal of time and effort learning regula-
tions, understanding the local market-
place and how to solve problems for
their clients. It almost seems a waste
not to share that knowledge with as
wide an audience as possible. Because
homebuying is the largest purchase most
people make in their lifetime, there is an
ongoing appetite for this type of informa-
tion. And a variety of medianewspa-
pers, Web sites, and television and radio
news outletshave and will continue to
feed that appetite by covering the topic of
homebuying.
Some deride public relations or pub-
licity as shameless self-promotion. And it
can be if the entire effort promotes only
yourself and your firm. Profile stories are
great, and can point out your success, and
how that success is based on helping
clients. But a profile is a one-time story.
Once the local paper runs a profile on you
or the firm, it could be many, many years
before it would even consider another
one, if ever.
The mortgage firms and advisors
which leverage the media the best are the
ones who promote not themselves, but
their expertise. The expertise shows up in
stories that address challenges that
homebuyers are facing. At a time when
the potential homebuyer is reading about
how to secure the lowest interest rate, he
or she reads a mortgage executives com-
mentary, and has that executive has just
been added to a short list of mortgage
pros they will call.
Successful mortgage pros view them-
selves as important advisors in the home-
buying process.
Most reporters, and just about all first-
time home buyers, dont have the same
intimate knowledge. Even second-time
buyers or those refinancing have general-
ly not kept up with changes since their
last mortgage application.
Not only are you promoting your
firm and your individual expertise, but
you are actually doing a favor for the
reporter. If done correctly, mortgage
advisors can be a valuable resource to
them over time. The real estate or per-
sonal finance reporters job is to pro-
vide their readership with useful infor-
mation that enables them to save time
and money. Its easy to see how that
overlaps with what the
mortgage firm and mort-
gage professionals goals
as well.
How to get
started
I Determine the local
media outlets where
real estate and home-
buying issues are dis-
cussed: Typically, this list
includes the local and
regional daily newspa-
pers, weekly newspapers,
and any local, news-ori-
ented Web sites. Also, to
be considered are busi-
ness publications are any
local TV or radio news
outlets. If increasing
referrals among account-
ants and attorneys is a
goal, regional trade pub-
lications reaching these
audiences can also be
included.
I Read or watch these media outlets:
Review their Web sites, and search
terms such as real estate, home-
buying and mortgages on these
sites. See which reporters have cov-
ered these areas and what types of
stories they write. In most cases, con-
tact information for reporters can be
gathered on the medias Web site. At
the larger media outlets, there
should be a reporter who covers real
estate or personal finance.
I Introduce yourself: Whether its via
phone or e-mail, simply state your
firm, who you are and your creden-
tials. Provide background on your
firm and on yourself. If representing
a mortgage firm, offer information
on individual mortgage professionals
and areas of specific expertise. Some
may specialize in home mortgages;
others in commercial lending; others
in Federal Housing Administration
(FHA) loans; or some on refinances.
Offer to be a source to the reporter
and list the topics upon which you or
your firm can comment. You can
even suggest an introductory meet-
ing. Aside from an initial phone call,
it is typically best to e-mail reporters
with ideas and information.
I Stay in touch, even if the initial con-
versation doesnt result in
an interview or meeting:
As you come across inter-
esting information, for-
ward it on to the
reporter. If you notice a
trend or any changes in
the local marketplace,
send that as well. If it is
an important develop-
ment, suggest that it may
make a good story for the
reporters readers. Regular
communicationsat least
once a month, but not
more than once a week
is vital. Help set the agen-
da for reporters. Its okay
to suggest stories, but just
as often, your role as
source is to provide an
update on whats going
on in the market. Help
the reporter connect the
dots. Heres an example:
You may have seen sta-
tistics about falling mortgage
approvals. Ive noticed a drop as
well, and attribute it to new con-
straints put on lenders because of
pressure from federal financial regu-
lators. My firm is still doing solid vol-
ume, but the approval process is
much more labor intensive these
days. If you are interested in a story
along these lines, I can provide fur-
ther commentary.
Dont be surprised if the reporter
doesnt response to your offer right
away. Ive had reporters call six
months after suggesting a story to
say that theyre now ready to work
on it. Even if the reporter doesnt
want to pursue a story suggestion
for whatever reason, he or she may
be working on a different story and
looking for insight or perspective. I
just happen to be working on a
story about the right time to refi-
nance, a reporter might say. Do
you work with homeowners on this
often? What kinds of advice do you
give them? If you dont specialize
in refinancing, refer the reporter to
someone in your network who can
answer the questions. Part of being
a valuable source is helping
reporters find appropriate sources.
They know that no one mortgage
professional will have expertise in
all areas. The reporters appreciate
your helpfulness.
Mortgage
professionals expend a
great deal of time and
effort learning
regulations,
understanding the local
marketplace and how
to solve problems for
their clients. It almost
seems a waste not to
share that knowledge
with as wide an
audience as possible.
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I Know what a reporter considers news-
worthy: Following a reporters cover-
age of the local real estate market
should provide a sense of what is wor-
thy of coverage. Usually it can be
summed up in one word: Changes.
Anything that deviates from the norm
(think man bites dog) is a candidate
for a story. Think changes in laws, reg-
ulations, interest rates, fees, and types
of mortgage options available.
I Provide examples of newsworthy infor-
mation that is available monthly: Every
month, real estate and personal
finance reporters write on the current
state of mortgage rates. This provides
an opportunity to contact these
reporters at least once a month to let
them know your thoughts on changes
to available rates and their effects on
would-be homebuyers and refinancing
plans.
I A clients problem may also illustrate an
issue of interest: Heres an example: Im
working on more FHA applications than
ever before. Many of these folks are now
self-employed or under-employed, and
are going the FHA route.
I Alert reporters to changes in regulations,
or proposed changes in regulation:
Reporters are busy and may not be
aware of a major piece of regulatory
reform being proposed. Let them
know whats being suggested, the
impetus for it, and the expected ram-
ifications. If you have a position for
or against this, great. If not, thats
okay as well. As long as you can put
the proposed rules in context. Will it
have an impact on homebuyers and
their ability to get a mortgage? Will it
increase costs? These are just some of
the questions a reporter will have.
The more you can answer them, the
quicker youll rise in their rank of
go-to sources.
Some opportunities will be based
on news, such as drops or increases
in interest rates. Some will be more
feature-oriented and less timely.
Here are just three examples.
O 15-year, 30-year, ARM? Deciding
the best mortgage for you
O New rules, more documentation:
Stricter standards means more
paperwork for buyers
O Top five tips for ensuring a smooth
mortgage
I When working with reporters, etiquette
and ethics are important: There are
several unwritten rules for working
with reporters. When offering ideas
and information, dont send one mass
e-mail to them. Ideally, you are foster-
ing individual relationships with all of
these reporters. Some will devote
more time and space to real estate
issues; some only cover news-related
items; others write features on home-
buying. Sending one e-mail to all
guarantees that a good portion of the
e-mails will be inappropriate.
If one reporter calls to get comments
for a specific story, dont share this
with competing reporters. Reporters at
different media outlets are very com-
petitive with one another. Disclosing
what one reporter is working on to
another is a series breach of trust.
I Be cognizant of a reporters deadlines:
The scene from the movie of the
reporter rushing to finish a story on
deadline is not Hollywood make-
believe. These folks are on deadline
just about every day or every week. If
you dont have time to speak with a
reporter immediately, ask when their
deadline is, and try your best to meet
it. If you cant, refer the interview to
someone else in your network.
Social media
Back in the day, a daily newspaper, TV
station or magazine used to be one of the
few ways to communicate to large audi-
ences. The advent of the Internet, and
more recently, the popularity of social
media allows for just about anyone to be
a publisher of online information.
There are many social media outlets
available to mortgage professionals,
including Facebook, LinkedIn, YouTube
and blogs. The social part of social media
is that these sites encourage a conversation
and allow for interaction. These sites pro-
vide a way to push content outwhether
it was created by the mortgage firm or by
someone else. Remember, content used
on social media sites should be similar in
nature to information used in the public
relations efforts. Its okay to provide con-
tent on you and your firm, but you need to
engage site visitors with information that
captures their interest. How many people
will come back repeatedly to read about
you and your products?
LinkedIn, primarily for business, has
Groups such as real estate attorneys and
accountants, designed for foster dia-
logues and share information.
YouTube has the ability for mortgage
firms and mortgage professionals to create
their own Channels. While boy coming
home from dentist videos still dominate,
more and more businesses are creating
channels to convey useful information. With
a task as important and personal as securing
a mortgage, providing a prospect the oppor-
tunity to see and hear directly from the
mortgage firm via video can be a big boost.
Like YouTube, more companies and
business professionals are using Facebook
to provide information and communicate
with past clients and prospects. Having
former clients Friend you and your busi-
ness is a tremendous marketing tool.
Having them post photos of the home
you helped them finance is even better.
Like the public relations effort, this
can take a great deal of work. The good
news again is that you dont have to use
every social media tool available. You
can focus on Facebook, or a blog or what-
ever one you believe is most useful.
Bob Zeitlinger is the founder and manag-
ing director of B to Z Communications, a
full-service public relations firm in north-
ern New Jersey. Zeitlinger has more than
20 years media relations and marketing
experience for a variety of clients in the
financial and professional services indus-
tries. He may be reached by phone at (201)
244-1213 or e-mail bzeitlinger@b2zcom-
munications.com.
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Interview Dos and Donts
I Prior to an interview, draft brief message points that provide reminders of
the key points to be made. Any singular topic can have many facets. Theres
nothing wrong with a cheat sheet that reminds you of the different aspects
of an issue to be discussed. Although you may know the general topic or
thrust of the reporters story, you may be unsure of other areas will be cov-
ered in the interview. Dont be shy about asking the reporter. Reporters are
used to this question and dont mind answering it. Remember you want
to be prepared. It makes the interview time more productive.
I After the interview, follow up with the reporter to make sure he or she has
everything they need. Its okay to guide or redirect the interview, especially
if the reporter is basing their line of questions on an incorrect assumption.
I Answer the question directly, and then provide details. Dont make the
reporter listen to an answer for three minutes to get the answer to a ques-
tion. The short answer is yes, and heres why
I Speak from experience. The interview is more genuine when you answer
questions in the context of a real client challenge. And they dont need to
mention the client by name to do this. I have many clients who face that
same problem, and here is what I tell them.
I Dont answer any questions, with just an It depends. Reporter: What type
of mortgage is best for a first-time homebuyer? Mortgage pro: It depends.
While thats accurate, its not helpful to the reporter. Its better to say, Thats
not a simple question to answer. For some, a 30-year fixed is best. For oth-
ers, an adjustable-rate mortgage (ARM) is best. Heres the type of person best
suited for each
I Avoid speaking off the record. If you dont want it in print, dont say it. There
are exceptions, but in general, its best to abide by this rule.
I If possible, point out what is new or different about the topic being dis-
cussed. Heres an example: Banks may have been reticent to approve cer-
tain types of mortgages, but are now being pressured by regulators to rein-
vest in their communities.
I Avoid the use of jargon or technical terms. If its unavoidable, make sure you
explain what they mean right away.
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nmp news flash continued from page 35
this pool is steadily growing smaller as a
percent of total loans outstanding. In
addition, employment is the key driver
of mortgage performance and the mort-
gage delinquency rate is actually falling
faster than the unemployment rate is
declining.
Delinquency Rate Hits
Highest Mark Since 2009
According to TransUnion,
the national mortgage
delinquency rate, defined
by TransUnion as the
rate of borrowers 60 or
more days past due, increased for only
the second time since the end of 2009,
edging upward to 6.01 percent at the
end of the fourth quarter in 2011.
Between the third and fourth quarters
of 2011, all but 13 states experienced
increases in their mortgage delinquency
rates. On a more granular level, 64 per-
cent of metropolitan areas saw increas-
es in their mortgage delinquency rates
in the fourth quarter of 2011. This is the
same percentage as found in Q3 2011,
but up from Q2 2011 when only 21 per-
cent of MSAs experienced an increase.
TransUnions forecast is based on
various economic assumptions, such as
gross state product, consumer senti-
ment, unemployment rates, real per-
sonal income, and real estate values.
The forecast would change if there are
unanticipated shocks to the economy
affecting recovery in the housing mar-
ket or if home prices fall more than
expected.
To see that, quarter over quarter,
fewer homeowners were able to make
their mortgage payments is not wel-
come news, said Tim Martin, group
vice president of U.S. housing in
TransUnions financial services business
unit. However, it was not unexpected.
First, there tends to be a natural sea-
sonality, evident well before the reces-
sion, of higher delinquencies in the
fourth quarter; perhaps explained by
borrowers balancing holiday spending
versus debt payments. Secondly, on the
economic front, house prices continued
to deteriorate in the fourth quarter and
unemployment remained stubbornly
high. This combination leads to more
negative equity in homes and reduced
real personal income that can affect
borrowers ability and willingness to
pay their mortgages.
Many see the economic environment
beginning to brighten, although mod-
estly. Therefore, TransUnions forecast
predicts mortgage borrower delinquen-
cy rates to drift downward marginally in
2012, but in the meantime we may still
see a quarter or two of slightly elevated
nonpayment rates as some consumers
are not able to, or decide not to, repay
their mortgage debt obligations in light
of the uncertain economic outlook.
The more encouraging news is that,
when looking year over year, more
homeowners are making their mort-
gage payments and the delinquency
rate dropped over six percent since Q4
2010, said Martin. While it is certainly
good to see the rate dropping, at this
pace it will take a very long time for
mortgage delinquencies to get back to
normal.
830,000 Foreclosures
Completed in 2011
CoreLogic has released
its first national Fore-
closure Report which
provides monthly data
on completed foreclo-
sures, foreclosure inventory and 90-
plus delinquency rates. Completed fore-
closures for all of 2011 totaled 830,000
compared with 1.1 million in 2010. In
December 2011, there was a month-
over-month decrease in completed
foreclosures to 55,000 from 57,000 in
November 2011. The December 2011
completed foreclosures figure was also
down from one year ago when it stood
at 67,000. From the start of the finan-
cial crisis in September 2008, there
have been approximately 3.2 million
completed foreclosures.
The new data from CoreLogic also
shows that nationally 1.4 million
homes, or 3.4 percent of all homes with
a mortgage, were in the foreclosure
inventory as of December 2011. The
foreclosure inventory is the stock of
homes in the foreclosure process. A
property moves into the foreclosure
inventory when the mortgage servicer
places the property into the foreclosure
process after serious delinquency is
reached and remains there until the
foreclosure is completed. The foreclo-
sure inventory is measured only against
homes with an outstanding mortgage,
rather than against all homes.
Nationwide, roughly one-third of
homeowners own their homes outright.
Nationally, the number of loans in
the foreclosure inventory decreased 8.4
percent in December 2011 compared to
December 2010, a decline of 130,000
properties nationwide. The number of
loans in the foreclosure inventory
decreased by 5.3 percent in November
2011 compared to November 2010 as
well.
The share of borrowers nationally
that were 90 days or more delinquent
on their mortgage payments, classi-
fied as seriously delinquent, improved
to 7.3 percent in December 2011 com-
pared to 7.8 percent in December
2010.
The inventory of foreclosed proper-
ties has begun to shrink, and the pace
at which properties are entering fore-
closure is slowing. While foreclosure fil-
ings are being curtailed by a variety of
judicial and regulatory constraints,
mortgage servicers are completing REO
sales faster than they are completing
foreclosures, said Mark Fleming, chief
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harp 2.0 continued from page 28
or outbound call campaign. We are cur-
rently seeing more than 2.5 percent
responses with marketing campaigns to
current Fannie Mae and Freddie Mac loan
holders. Once this new plan launches in
full force and major news outlets begin
reporting on the program, the excitement
should drive direct mail responses up
well over the three percent mark.
The above-stated numbers provide
us with a couple important things to
consider. First, there will be at least 11
million homeowners (that you can
help) that may be searching online for
HARP rates at any given time from now
until the end of 2013. It is your job to
capture that search, either by your own
page or through a company that can
help you capture those leads. Second,
the above numbers also let us know
how many people you can market to
through direct mail campaigns, as well
as cold calling campaigns.
If you set up your direct marketing
programs correctly with the right part-
ners, HARP will be bigger than you
could have imagined!
Raymond Bartreau is chief executive offi-
cer of BestRate Referrals, and founder
and chief executive officer of www.harp-
mortgageleads.com. He may be reached
by phone at (800) 811-1402 or e-mail
RBartreau@BestRateReferrals.com.
economist with CoreLogic. This is the
first time in a year that REO sales have
outpaced completed foreclosures, and
part of the reason for the decrease in
the foreclosure inventory.
FHFA Issues Its Plans for
the GSEs to Congress
Federal Housing
Finance Agency
(FHFA) Acting
Director Edward
J. DeMarco has
issued a strate-
gic plan for the next phase of the con-
servatorships of the government-
sponsored enterprises (GSEs), Fannie
Mae and Freddie Mac, to Congress.
The plan builds on DeMarcos
February 2010 letter to Congress on
the conservatorships and sets forth
objectives and steps that the FHFA is
taking or will take to meet its obliga-
tions as conservator. Fannie Mae and
Freddie Mac were placed into conser-
vatorship on Sept. 6, 2008 and have
since received more than $180 bil-
lion in taxpayer support.
MBA welcomes FHFAs proposal for
the next phase of the conservatorship
of Fannie Mae and Freddie Mac, said
David H. Stevens, president and chief
executive officer of the Mortgage
Bankers Association (MBA). We have
been out front on GSE reform issues,
and our Council on Ensuring Mortgage
Liquidity outlined many of these same
types of changes in its September 2009
proposal on the future of the govern-
ments role in the secondary mortgage
market.
The FHFA identifies three strategic
goals for the next phase of the con-
servatorships:
I Build a new infrastructure for the
secondary mortgage market;
I Gradually contract the GSEs domi-
nant presence in the marketplace
while simplifying and shrinking their
operations; and
I Maintain foreclosure prevention
activities and credit availability for
new and refinanced mortgages.
With the conservatorships operat-
ing for more than three years and no
near-term resolution in sight, it is
time to update and extend the goals
and directions of the conservator-
ships, said DeMarco. FHFA is con-
templating next steps to build an
infrastructure for the secondary mort-
gage market that is consistent with
existing policy proposals and will sup-
port any outcome of the leading leg-
islative proposals. FHFA looks forward
to working with Congress and the
Administration on a resolution of the
conservatorships and a comprehen-
sive review of the nations housing
finance system.
Stevens continued, Uncertainty,
wherever it exists, must be removed
and a clear path forward must be laid
out, in order for the housing market in
this country to be strong and vibrant.
This proposal that FHFA is putting forth
shows a strong commitment to doing
just that.
Illinois AG Madigan Files
Suit Against S&P for Risky
MBS Ratings
Illinois Attorney Gen-
eral Lisa Madigan has
filed a lawsuit
against Standard & Poors (S&P) for its
fraudulent role in assigning its highest
ratings to risky mortgage-backed securi-
ties (MBS) in the years leading up to the
housing market crash. Madigan filed
her suit in Cook County Circuit Court,
alleging that S&P compromised its inde-
pendence as a ratings agency by doling
out high ratings to unworthy, risky
investments as a corporate strategy to
increase its revenue and market share.
The Attorney Generals lawsuit alleges
that S&P ignored the increasing risks
posed by MBS, instead giving the invest-
ment pools ratings that were favorable
to its investment bank client base and
S&Ps profits.
Publically, S&P took every oppor-
tunity to proclaim their analyses and
ratings as independent, objective and
free from its desire for revenue, AG
Madigan said. Yet privately, S&P
abandoned its principles and instead
used every trick possible to give deals
high ratings in order to retain clients
and generate revenue. The mortgage-
backed securities that helped our mar-
ket soarand ultimately crash
could not have been purchased by
most investors without S&Ps seal of
approval.
AG Madigans suit cites numerous
internal e-mails and conversations
among S&P employees in the run up to
the housing markets crash that demon-
strate the company misrepresented its
ratings as objective and independent. In
one such exchange, in April 2007, an
online conversation via a company-
based instant messenger application
revealed employees discussing S&P rat-
ings compared to the reality of risk
involved, with an employee stating an
investment could be structured by
cows and we would rate it.
Madigan said investors relied on S&P
ratings because they were historically
rooted in the agencys purported inde-
pendence and objectivity. S&Ps inter-
nal code of conduct states its goal to
promote investor protection by safe-
guarding the integrity of the rating
process. But, the Attorney Generals
lawsuit cites congressional testimony by
a former managing director of S&P who
revealed that profits were running the
show, with ratings being assigned to
risky investments to help drive profit
margins for their clients.
S&P, a subsidiary of McGraw-Hill
Companies, is one of the nations
largest credit ratings agencies respon-
sible for independently rating risk on
behalf of clients and investors.
Madigan said in the run up to the
financial crisis, S&P consistently mis-
represented the risk of MBS, assigning
these securities its highest seal of
approvalor AAA rating. This misrep-
resentation spurred investors to pur-
chase securities that were far riskier
than their ratings revealed.
Bill Introduced to STOP
Excessive GSE Bonuses
U.S. Sens. Mark Begich
(D-AK) and John Thune
(R-SD) have introduced
SB 2054, the Stop the
Outrageous Pay (STOP)
at Fannie Mae and
Freddie Mac Act, and act which prevents
the distribution of undisbursed bonus
money and moves all Fannie Mae and
Freddie Mac employees onto a struc-
tured pay scale similar to that of other
federal financial regulators. The Begich-
Thune bill follows a series of events
from November of 2011, when reports
surfaced that the Federal Housing
Finance Agency (FHFA) approved near-
ly $13 million in bonus pay for 10 exec-
utives at Fannie and Freddie. In
response, Sens. Begich and Thune
spearheaded a bi-partisan letter,
signed by a total of 60 senators, to
FHFA Acting Director Edward J.
DeMarco and Treasury Secretary
Timothy Geithner expressing outrage
over the excessive pay.
Our goal is to make sure the reck-
less and outrageous bonuses issued
to Fannie and Freddie execs last year
are never repeated and remain a his-
tory lesson on abuse of taxpayer
money, Sen. Begich said. The two
agencies have received over $150 bil-
lion in taxpayer funds since 2008,
and those executives should not be
living like fat cats while many
Alaskans and other Americans are
struggling to pay their bills, send
their kids to college, and make the
mortgage payment.
The Begich-Thune STOP Act suspends
the current compensation packages of
Fannie and Freddie executives and lim-
its the pay for all employees.
Specifically, SB 2054:
I Places all employees of Fannie Mae
and Freddie Mac on the pay scale
used by the federal financial regula-
tors such as the FDIC and the SEC, as
established by the Financial
Institutions Reform, Recovery, and
Enforcement Act (FIRREA) of 1989.
Under this pay scale, Fannie Mae
and Freddie Mac employees would
be prohibited from being paid
more than employees of other fed-
eral financial regulatory agencies
(currently capped at $275,000
annually);
I Prevents any future pay or bonus
payments for 2011 and beyond that
are in excess of this new pay cap and
that have not yet been disbursed.
These funds would be used to pay
down the national debt; and
I Requires the FHFA to make Fannie
Mae and Freddie Mac salary dis-
bursements data available to
Congress and the public without
compromising the privacy of individ-
ual employees.
It is unbelievable that Congress
needs to step in and end these outra-
geous salaries for Fannie Mae and
Freddie Mac executives, said Sen.
Thune. The American taxpayers have
already bailed out these agencies to
the tune of over $150 billion and
should not be on the hook for mil-
lions of dollars in exorbitant salaries.
The House Financial Services
Committee passed similar legislation to
suspend the bonuses and limit future
compensation packages by a vote of 52-
4 on Nov. 15, 2011.
Your turn
National Mortgage Professional
Magazine invites you to submit any
information on regulatory changes, leg-
islative updates, human interest stories
or any other newsworthy items pertain-
ing to the mortgage industry to the
attention of:
NMP News Flash column
Phone #: (516) 409-5555
E-mail:
newsroom@nmpmediacorp.com
Note: Submissions sent via e-mail are pre-
ferred. The deadline for submissions is the
1st of the month prior to the target issue.
40
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By Jonathan Foxx
A new era in filing
requirements is about
to begin. For the first
time, the Financial
Crimes Enforcement
Network (FinCEN) will
require non-bank mortgage lenders and
originators to implement an Anti-Money
Laundering program (AML Program)
and file Suspicious Activity Reports
(SARs) for certain loan transactions.
1
FinCEN is establishing this AML pro-
gram in accordance with the Bank
Secrecy Act (BSA).
2
The guidelines relat-
ing to the AML requirement become
effective on April 16, 2012, and the AML
Programs effective compliance date is
Aug. 13, 2012.
3
The AML program and
SAR filing regulations, which I will refer
to as FinCENs rule, are considered to
be the first step in an incremental
approach to implementation of regula-
tions for the broad loan or finance com-
pany category of financial institutions.
4
The Bank Secrecy Act defines the
term financial institution to include,
in part, a loan or finance company. This
terminology, however, can reasonably
be construed to extend to any business
entity that makes loans to or finances
purchases on behalf of consumers and
businesses. Thus, non-bank residential
mortgage lenders and originators, and
mortgage brokers, are grouped into the
loan or finance company category.
5
However, the term loan or finance
company is actually not concisely
defined in any FinCEN regulation, and
there is no legislative history on the
term itself. Nevertheless, FinCEN is
applying this term to extend to any
business entity that makes loans to or
finances purchases on behalf of con-
sumers and businesses.
6
Therefore, res-
idential mortgage lenders and origina-
tors (RMLOs) are covered by the scope
of the loan or finance company term.
I will use the acronym RMLO in this
article, inasmuch as my principal focus
herein relates to residential mortgage
lenders and originators.
FinCEN can issue regulations requir-
ing financial institutions to keep
records and file reports that are deter-
mined to have a high degree of useful-
ness in criminal, tax, or regulatory
investigations or proceedings, or in the
conduct of intelligence or counterintel-
ligence activities, including analysis, to
protect against international terrorism.
Federally-regulated depository institu-
tions have been required to have AML
Programs,
7
and now, as of the afore-
mentioned effective compliance date,
RMLOs must also comply with FinCENs
regulations relating to implementing an
AML Program and the filing of SARs.
Over the last few years,
8
FinCEN has
issued studies and analyses that used
SARs to discover suspected mortgage
fraud and money laundering that
involved both banks and residential
mortgage lenders and originators.
9
According to FinCEN, these reports
underscore[d] the potential benefits of
AML and SAR regulations for a variety of
businesses in the primary and second-
ary residential mortgage markets.
10
Residential mortgage lenders and
originators, the RMLOs, are considered to
be the primary providers of mortgage
finance, and have a unique position with
respect to direct contact with the con-
sumer. Thus, they are presumably able to
assess and identify money laundering
risks and fraud.
11
At this time, FinCEN is
not proposing a definition of loan or
finance company that would encompass
other types of consumer or commercial
finance companies, or real estate agents
and other entities involved in real estate
closings and settlements.
In this article, I am going to unpack
the AML Program for you in a way that
will give you some familiarity with its
scope, while perhaps also making its
implementation a bit less daunting
than it might otherwise seem to be.
Nevertheless, many RMLOs will find that
setting up the AML Program will be a
challenging endeavor. Information,
issuances, and relevant documentation
are available in the FinCEN section of
my firms Web site Library at
LendersComplianceGroup.com.
Please keep in mind that, as is the case
with many applications of legal and reg-
ulatory compliance, there are aspects
and nuances that will require recourse to
a competent risk management profes-
sional to obtain comprehensive guidance
and reliable information.
12
AML Program
Residential mortgage lenders and origi-
nators, the RMLOs, are required to
establish an AML Program that includes,
at a minimum:
1. Development of internal policies,
procedures, and controls.
2. Designation of a compliance officer.
3. Ongoing employee training program.
4. Independent audit function to test
for compliance.
To effectuate the AML Program,
FinCEN has given a definition of an
RMLO that is broad in scope and covers
most non-bank residential mortgage
originators.
The AML Program covers any busi-
ness that, on behalf of one or more
lenders, accepts a completed mortgage
loan application, even if the business
does not in any manner engage in nego-
tiating the terms of a loan. Also covered
are businesses that offer or negotiate
specific loan terms on behalf of either a
lender or borrower, regardless of
whether they also accept a mortgage
loan application.
Note that the word accept is
intended to differentiate the FinCEN
rule from the SAFE Act. FinCEN is ensur-
ing that persons who either accept an
application or offer or negotiate the
terms of a loan are covered.
Furthermore, the AML rule applies to
residential mortgage originators,
regardless of whether they receive com-
pensation or gain for acting in that
capacity.
Obviously, these changes create dif-
ferences between the definitions in the
FinCEN rule and those used in the SAFE
Act and other federal mortgage-related
statutes. Clearly, this was done inten-
tionally to differentiate the FinCEN
requirements from those other statutes,
so that FinCENs interpretation is not
based on the interpretation of those
statutes.
13
Moreover, FinCEN has taken
the position that the registration and
training requirements under the SAFE
Act are not sufficient to address all of
the concerns and accomplish all of the
goals related to AML and SAR programs.
In any event, FinCEN has announced
that it intends to dialogue with the
Conference of State Bank Supervisors
(CSBS) to coordinate the identification
and examination of mortgage origina-
tors subject to FinCENs rule.
14
The AML Program applies to busi-
nesses, including sole proprietorships,
but does not contemplate coverage of
an individual employed by a financial
institution.
15
To state this precisely:
FinCENs rule does not incorporate any
exceptions for businesses based on
their form of organization.
There are no exceptions for a certain
arbitrary number of employees or net
worth, nor is there a small business
exclusion or exception for businesses
with fewer than five employees, or for
businesses that satisfy some other arbi-
trary size, net worth or similar criteria.
Similarly, there is no de minimis
exception for businesses that lend or
broker loans under a relatively low
value, or low aggregate volume of
transactions within a set time period.
The only exclusion is given to individu-
als financing the sale of their own real
estate.
Generally, purchase money mort-
gage loans and traditional refinancing
transactions facilitated by RMLOs are
covered in the AML Program. Yet,
because any transactions conducted by
the RMLO could reasonably be consid-
ered to be extending a residential mort-
gage loan or offering or negotiating the
terms of a residential mortgage loan,
within the meaning of the definitions of
residential mortgage lender and res-
idential mortgage originator, as pro-
vided in FinCENs rule, the AML
Program would seem to apply to trans-
actions involving funds or programs
under the Troubled Asset Relief
Program (TARP) and similar federal pro-
grams, or any similar state housing
authority or housing assistance pro-
gram. However, to the contrary,
FinCENs rule does not directly apply to
the federal or state housing authorities
and agencies administering such pro-
grams. Therefore, excluded from the
AML Program is any federal or state
agency or authority administering
mortgage or housing assistance, fraud
prevention or foreclosure prevention
program, though RMLOs participating
in such programs must comply with
Anti-Money Laundering Debuts for Non-Banks
41
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FinCENs rule to the extent that any
transactions could reasonably be con-
sidered to be extending a residential
mortgage loan or offering or negotiat-
ing the terms of a residential mortgage
loan.
16
Interestingly, the AML Program does
apply to foreclosure prevention actions
and counseling services performed by
legitimate, non-profit organizations, to
the extent any such organizations may
reasonably be deemed to be extending
a residential mortgage loan (including a
short-term mortgage loan), or offering
or negotiating the terms of a residential
mortgage loan. However, FinCENs rule
does not require implementation of the
AML Program rules for non-profit
organizations that:
1. Limit their activities to assisting with
the preparation of loan applications
or referral of prospective borrowers
to qualified lenders, for free or for a
fee;
2. Provide short-term, non-mortgage
loans to qualified borrowers or
homeowners, or
3. Otherwise facilitate the extension
of a residential mortgage loan (but
do not make the loan or offer or
negotiate the terms of the loan).
Apparently, mortgage servicers are
in a grey area with respect to complying
with the FinCEN rule. Although FinCEN
seems to agree that the typical activities
of mortgage servicing companies do
not fall within the definition of residen-
tial mortgage originator, FinCEN will
not make a blanket exclusion or
exception for mortgage servicers. That
is, because the broad definition is
based on the activity in which an entity
is engaged, as long as a mortgage ser-
vicer does not extend residential mort-
gage loans or offer or negotiate the
terms of a residential mortgage loan
application, it will not fall under of the
definition of residential mortgage loan
originator.
Loan modification programs, such as
the Home Affordable Modification
Program (HAMP) are covered by FinCENs
rule only to the extent that the modifica-
tions do not involve extending new resi-
dential mortgage loans or offering or
negotiating the terms of a residential
mortgage loan application. Such pro-
grams nonetheless are vulnerable to
fraud and money laundering; in fact,
since 2009, FinCEN has warned financial
institutions and consumers about the
fraud and money laundering risks associ-
ated with foreclosure prevention and
loan modification programs.
17
Suspicious Activity Report
Before we move on to an outline of the
AML Program, let us take a close look at
the form that must be filed with
FinCEN. This form is called the
Suspicious Activity Report, known as a
SAR. FinCEN had considered requiring
RMLOs to use Treasury SAR Form TD F
90-22.47, the form presently used by
banks and other insured depository
institutions.
18
For FinCENs purposes,
the information required for a SAR from
an RMLO would be substantially the
same as that required of banks and
other depository institutions that make
mortgage loans and use SAR Form TD F
90-22.47.
19
The Federal financial institutions
regulatory agencies, the U.S.
Departments of Justice, and the
Treasury, may use and share the infor-
mation collected on a SAR.
In my experience with bank clients,
the time required for collecting infor-
mation averages 30 to 45 min. per SAR
response, and that includes the time to
gather and maintain data in the
required SAR report, review the instruc-
tions, and complete the reports fields. I
think the same time frame will likely
apply to non-bank SARs.
However, FinCEN is modernizing its
SAR filing system and intends to estab-
lish a uniform electronic form for use by
all financial institutions with a SAR fil-
ing obligation.
20
Accordingly, FinCEN
promulgated the aforementioned,
effective compliance date for SAR filing
in order to allow time for the non-bank
industry to implement programs and
systems and for FinCEN to implement
the new filing system using a uniform
SAR.
In addition, FinCEN intends to phase
out the manual filing of paper SAR
forms.
21
Therefore, RMLOs will be
required to use FinCENs electronic,
Web-based E-Filing system, which is cur-
rently under development, for the filing
of the SAR form. The E-Filing system will
be Web-based and will not require auto-
mated systems to be integrated into the
loan origination systems.
The current SAR consists of five parts,
as follows:
I Part I: Reporting Financial Institution
Information
I Part II: Suspect Information
I Part III: Suspicious Activity Information
I Part IV: Contact for Assistance
I Part V: Suspicious Activity Information
Explanation/Description
Completing the SAR correctly is
essential to compliance with FinCENs
rule. A whole cottage industry of inde-
pendent auditors has built up over the
years to review a banks compliance
with respect to SAR filings. This auditing
is essential, however, as there is a req-
uisite independent testing component
to any valid AML Program, whether
bank or non-bank.
For an example of meticulous due
diligence in completing a SAR, the SARs
Part V section itself requires careful
explanation and/or description of
known or suspected violation of law or
suspicious activity and the care with
which it is completed may make the dif-
ference in whether or not the described
conduct and its possible criminal nature
are clearly understood and recorded.
Thus, the SAR forms preparation and
filing, although conducted by the
RMLOs employees, often requires inde-
pendent auditors to determine and
report on the enforcement of the AML
Program and the accuracy, complete-
ness, and timeliness of the SAR filings.
My firm conducts such audits, and I
can attest to the wide range of under-
standing on the part of our clients
regarding, among other things, the
comprehensiveness of the AML Pro-
gram, what information requires a SAR
filing, the obligation of filing a SAR in a
particular instance, how and when a
SAR must be or should have been filed,
and the extent to which employees are
adequately educated in Bank Secrecy
Act mandates.
Safe Harbor
There are some features of filing a SAR
that have stirred controversy and pro-
voked litigation over the years, especial-
ly in the areas of the Safe Harbor, lim-
itation on liability, and notification to
the suspect of a subject SAR being filed.
There is a Safe Harbor under feder-
al law
22
that provides complete protec-
tion from civil liability for all reports of
suspicious activity transactions made to
appropriate authorities, including sup-
porting documentation, regardless of
whether such reports are filed pursuant
to the SARs instructions or are filed on
a voluntary basis. Specifically, the law
provides that a financial institution,
and its directors, officers, employees
and agents, that make a disclosure of
any possible violation of law or regula-
tion, including in connection with the
preparation of suspicious activity
reports, shall not be liable to any per-
son under any law or regulation of the
United States, any constitution, law, or
regulation of any state or political sub-
division of any state, or under any con-
tract or other legally enforceable agree-
ment (including any arbitration agree-
ment), for such disclosure or for any
failure to provide notice of such disclo-
sure to the person who is the subject of
such disclosure or any other person
identified in the disclosure.
An RMLO, and any director, officer,
employee, or agent of any loan or
finance company, that makes a volun-
tary disclosure of any possible violation
of law or regulation to a government
agency or makes a disclosure pursuant
to FinCENs rule or any other authority,
including a disclosure made jointly
with another institution, is protected
from liability for any such disclosure, or
for failure to provide notice of such dis-
closure to any person identified in the
disclosure, or both.
23
Notifying the suspect of
suspicious activity
Notification to the suspect is prohibited
under federal law
24
and a financial insti-
tution, and its directors, officers,
employees and agents that, voluntarily
or by means of filing a SAR, report sus-
pected or known criminal violations or
suspicious activities may not notify any
person involved in the transaction that
the transaction has been reported.
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continued on page 42
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Indeed, any RMLO, and any director,
officer, employee, or agent of an RMLO,
if subpoenaed or otherwise requested
to disclose a SAR or any information
that would reveal the existence of a
SAR, must decline to produce the SAR
or any information relating to the sub-
ject SAR. The required response of the
RMLO to such circumstances is to notify
FinCEN of any such request and report-
ing to FinCEN the response thereto
made thus far by the RMLO.
25
Furthermore, there is a prohibition
to sharing by an RMLO, or any director,
officer, employee, or agent of the
RMLO, of a SAR, or any information that
would reveal the existence of a SAR,
within the RMLOs own corporate orga-
nizational structure.
26
There are even prohibitions involv-
ing government entities with respect to
SAR disclosure. A federal, state, local,
territorial, or tribal government author-
ity, or any director, officer, employee,
or agent of any of the foregoing, may
not disclose a SAR, or any information
that would reveal the existence of a
SAR, except as necessary to fulfill offi-
cial duties consistent with the Bank
Secrecy Act.
27
Official duties, however,
do not include the disclosure of a SAR,
or any information that would reveal
the existence of a SAR, in response to a
request for disclosure of non-public
information or a request for use in a
private legal proceeding.
28
AML Program
Components
I propose now to provide an overview
of the components of the AML Program,
as mandated in FinCENs rule. Please
keep in mind that each component
contains numerous integrative subsets
and various compliance elements that
must be coherently and logistically
enforced, each of which is subject to
independent testing and verification.
The AML Program for RMLOs
requires, in the first place, a written
anti-money laundering program that is
reasonably designed to prevent the
RMLO from being used to facilitate
money laundering or the financing of
terrorist activities. Senior management
must approve the AML Program and,
upon request, a copy of it must be
made available to FinCEN (or its
designee).
The following four components con-
stitute the core requirements of the
AML Program. Failure to comply fully
with implementing these components
on and after Aug. 13, 2012 may consti-
tute a violation of the Bank Secrecy Act.
I have titled each component to reflect
its essential significance.
Internal control plan
Incorporate policies, procedures, and
internal controls based upon the
RMLOs assessment of the money laun-
dering and terrorist financing risks
associated with its products and servic-
es. Policies, procedures, and internal
controls developed and implemented
by an RMLO must include provisions for
complying with the applicable require-
ments
29
of integrating the companys
agents and brokers into its AML
Program, and obtaining all relevant
customer-related information necessary
for an effective AML Program.
BSA officer
Designate a compliance officer who will
be responsible for ensuring that:
1. The RMLOs AML Program is imple-
mented effectively, including moni-
toring compliance by the companys
agents and brokers with their obliga-
tions under the program;
2. The AML Program is updated, as nec-
essary; and,
3. Appropriate persons are educated
and properly trained.
Training
Provide for ongoing training of appro-
priate persons concerning their respon-
sibilities under the AML Program. An
RMLO may satisfy this requirement with
respect to its employees, agents, and
brokers by directly training such per-
sons or verifying that such persons have
received training by a competent third
party with respect to the products and
services offered by the RMLO.
Independent testing
Provide for independent testing to
monitor and maintain an adequate
AML Program, including testing to
determine compliance of the compa-
nys agents and brokers with their obli-
gations under the AML Program. The
scope and frequency of the testing must
be commensurate with the risks posed
by the RMLOs products and services.
Such testing may be conducted by a
third party or by any officer or employ-
ee of the RMLO, other than the person
designated as the BSA officer.
Filing the SAR
Commencing with the compliance date
of Aug. 13, 2012, every RMLO is required
to file a SAR with FinCEN, pursuant to
the FinCENs rule. An RMLO may also file
a SAR that it believes is relevant to the
possible violation of any law or regula-
tion, but whose reporting is not actual-
ly required. The AML Program should
provide clear and unambiguous proce-
dures to identify such instances.
A transaction
30
requires reporting if it
is conducted or attempted by, at, or
through an RMLO, it involves or aggre-
gates funds or other assets of at least
$5,000, and the RMLO knows, suspects,
or has reason to suspect that the trans-
action (or a pattern of transactions of
which the transaction is a part):
1. Involves funds derived from illegal
activity or is intended or conducted
in order to hide or disguise funds or
assets derived from illegal activity
(including, without limitation, the
ownership, nature, source, location,
or control of such funds or assets) as
part of a plan to violate or evade
any Federal law or regulation or to
avoid any transaction reporting
requirement under Federal law or
regulation.
2. Is designed, whether through struc-
turing or other means, to evade any
requirements of this part or any
other regulations promulgated under
the Bank Secrecy Act.
31
3. Has no business or apparent lawful
purpose or is not the sort of purpose
in which the particular customer
would normally be expected to
engage, and the RMLO knows of no
reasonable explanation for the trans-
action after examining the available
facts, including the background and
possible purpose of the transaction.
4. Involves use of the RMLO to facilitate
criminal activity.
It should be noted that more than
one RMLO may have an obligation to
report the same transaction, and actu-
ally other financial institutions may
have separate obligations to report sus-
picious activity with respect to the same
transaction pursuant to other FinCEN
provisions. In those instances, no more
than one report is required to be filed
by the RMLO and other financial institu-
tions involved in the transaction, pro-
vided that the filed report contains all
relevant facts, including the name of
each financial institution involved in
the transaction, the SAR complies with
all instructions applicable to joint fil-
ings, and each institution maintains a
copy of the filed SAR, along with any
supporting documentation.
The SAR must be filed no later than
30 calendar days after the date of the
initial detection by the reporting RMLO
of facts that may constitute a basis for
filing a SAR. If no suspect is identified
on the date of such initial detection, an
RMLO may delay filing a SAR for an
additional 30 calendar days to identify
a suspect, but in no case may the
reporting be delayed more than 60 cal-
endar days after the date of the initial
detection.
There are mechanisms in place to
handle urgent circumstances. In situa-
tions involving violations that require
immediate attention, such as suspect-
ed terrorist financing or ongoing
money laundering schemes, an RMLO
is required to immediately notify by
telephone an appropriate law
enforcement authority, obviously in
addition to the timely filing of a SAR.
And voluntary notification to FinCEN
of suspicious transactions that may
relate to terrorist activity may be
directed to FinCENs Financial
Institutions Hotline at (866) 556-3974;
and, of course, such notification
would still require the RMLO to file
the subject SAR in a timely manner.
Record Retention
Record Retention provisions must be
included in the AML Program. The
RMLO must maintain a copy of any SAR
filed by the RMLO or on its behalf
(including joint reports), and the origi-
nal (or business record equivalent) of
any supporting documentation con-
cerning any SAR that it files (or is filed
on its behalf), for a period of five years
from the date of filing the SAR.
Supporting documentation should be
identified as such and maintained by
the RMLO, and would in any event be
deemed to have been filed with the
SAR.
The RMLO is required to make all
supporting documentation available to
FinCEN, or any Federal, state, or local
law enforcement agency, or any Federal
regulatory authority that examines the
RMLO for compliance with the Bank
Secrecy Act, or any state regulatory
authority administering a state law that
requires the RMLO to comply with the
Bank Secrecy Act or otherwise authoriz-
es the state authority to ensure that the
RMLO complies with the Bank Secrecy
Act, upon request.
Examinations
Federal prudential regulators have del-
egated authority to examine certain
financial institutions they oversee for
compliance with FinCENs regulations.
32
The Internal Revenue Service (IRS) has
also been delegated the authority to
examine for compliance with FinCENs
regulations those financial institutions
that are not examined by a federal
functional regulator.
33
SARs filed pursuant to FinCENs regu-
lations go into a database that is acces-
sible to regulatory agencies and law
enforcement on the federal, state and
local levels.
FinCEN has been considering various
options for delegating complete or par-
tial examination authorities over RMLOs
for compliance with the AML Program. In
addition to the IRS authority, some enti-
ties under consideration that may have
delegated supervision, examination, and
enforcement authority are state regula-
tory agencies, the Consumer Financial
Protection Bureau (CFPB), and the feder-
al banking agencies (particularly with
respect to RMLOs affiliated with banks or
insured depository institutions and their
holding companies).
A regulatory issuance from FinCEN is
forthcoming on the designated authori-
ties. FinCEN has announced that it
plans to work with other relevant regu-
latory agencies in the development of
consistent compliance examination
procedures, and in the future it will
provide public notice of other agencies
that will exercise delegated compliance
examination authority with respect to
certain classes of RMLOs and other loan
or finance companies.
Preparation
and readiness
It is important to develop a reliable
understanding about when an RMLO
should be required to file a particular
anti-money laundering continued from page 41
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SAR. In my view, a determination as to
whether a SAR is required must be based
on all the facts and circumstances relat-
ing to the transaction and customer of
the RMLO. Different fact patterns will
require different judgments.
Some examples of red flags are ref-
erenced in previous FinCEN reports on
mortgage fraud and money laundering
in the residential and commercial real
estate sectors. There are many identi-
fiers and special information proce-
dures that FinCEN has provided to iden-
tify suspicious activity.
34
Most RMLOs, in
order to remain viable, already have in
place policies and procedures to pre-
vent and detect fraud, insider abuse,
and other crimes. Established anti-
fraud measures should assist RMLOs in
reporting suspicious transactions.
The techniques of money laundering
and mortgage fraud are continually
evolving, and there is no way to provide
an exhaustive list of suspicious activity
transactions. A strong AML Program
should be sufficiently comprehensive in
its understanding of the RMLOs organi-
zational structure, business practices,
products, services, affiliates, con-
sumers, and vendors, to be able to
monitor for suspicious activity that may
involve fraud, money laundering, and
other financial crimes, without becom-
ing a burden to the effective and cost-
efficient operations of all affected
departments throughout the loan flow
process.
Jonathan Foxx, former chief compliance
officer for two of the countrys top pub-
licly-traded residential mortgage loan
originators, is the president and manag-
ing director of Lenders Compliance
Group, a mortgage risk management
firm devoted to providing regulatory
compliance advice and counsel to the
mortgage industry. He may be contacted
at (516) 442-3456 or by e-mail at
jfoxx@lenderscompliancegroup.com.
Footnotes
1See Federal Register sources for this article:
Anti-Money Laundering Program and Suspicious
Activity Report Filing Requirements for
Residential Mortgage Lenders and Originators,
Financial Crimes Enforcement Network,
Department of the Treasury, 31 CFR Parts 1010
and 1029, Final Rule, Federal Register, Vol. 77,
No. 30, 02/14/12; Anti-Money Laundering
Program and Suspicious Activity Report Filing
Requirements for Residential Mortgage Lenders
and Originators, Financial Crimes Enforcement
Network, Department of the Treasury, 31 CFR
Part 103, Notice of Proposed Rulemaking, Federal
Register, Vol. 75, No. 236, 12/09/10; Anti-Money
Laundering Program and Suspicious Activity
Report Requirements for Non-Bank Residential
Mortgage Lenders and Originators, Financial
Crimes Enforcement Network, Department of the
Treasury, 31 CFR Part 103, Advance Notice of
Proposed Rulemaking, Federal Register, Vol. 74,
No. 138, 07/21/09.
2Bank Secrecy Act is the name that has come
to be applied to the Currency and Foreign
Transactions Reporting Act (Titles I and II of
Public Law 91508), its amendments, and the
other statutes referring to the subject matter of
that Act. These statutes are codified at 12 U.S.C.
1829b, 12 U.S.C. 19511959, and 31 U.S.C. 5311
5314 and 53165332, and notes thereto.
3See 31 CFR 1029.210.
4FinCEN Requires AML Program and SAR Filing
for Non-Bank Mortgage Lenders and Originators,
News Release, Financial Crimes Enforcement
Network, 02/07/12.
531 U.S.C. 5312(a)(2)(P).
6The definition of loan or finance company
initially includes only these businesses, but is
broad enough to permit the addition of other
types of loan and finance related businesses and
professions in future rulemaking. Though not
included in the definition of loan and finance
companies, FinCEN has also proposed AML and
SAR reporting rules for the GSEs. Where fraud is
suspected by a GSE, there is an established proce-
dure, currently set forth in a Memorandum of
Understanding between FinCEN and the Federal
Housing Finance Agency (FHFA) for the GSE to
report to the FHFA, which then reports the suspi-
cious activity to FinCEN.
7A depositorys AML Program, as now constitut-
ed, is more robust with respect to BSA mandates
than that required for nonbanks. For instance,
included in a banks FinCEN Compliance is the fil-
ing of a Currency Transaction Report (CTR). It is
FinCENs view that filing a Currency Transaction
Report (CTR) is unnecessary for loan or finance
companies. Therefore, RMLOs do not need to
adopt CTR filing requirements into their AML
Programs.
8FinCEN commenced in 2006 its reporting on
mortgage fraud and RMLO money laundering.
9See, for instance, Mortgage Loan Fraud
Update (SARs Jan. 1-March 31, 2011), June 2011;
Mortgage Loan Fraud Update (SARs Jan. 1-Dec.
31, 2010), March 2011; Mortgage Loan Fraud
Update (SARs July 1-Sept. 30, 2010), January
2011; Mortgage Loan Fraud Update (SARs April
1-June 30, 2010), December 2010; and,
Mortgage Loan Fraud Update: SAR Filings Jan. 1-
March 31, 2010.
10Op. Cit. 4.
11FinCENs position is that the new regulations
will help mitigate some of the risks and minimize
some of the vulnerabilities that criminals have
exploited in the non-bank residential mortgage
sector, based on FinCENs criminal investigations
and prosecutions, other anti-fraud efforts, the
Financial Fraud Enforcement Task Force, and
recently the Residential Mortgage-Backed
Securities Working Group.
12For more information, visit the FinCEN sec-
tion of my firms Web site Library at
LendersComplianceGroup.com or contact us for
assistance.
13FinCEN has stated that it intends the defini-
tions in the its rule and subsequent amendments
thereto to be consistent with definitions in the
SAFE Act and other federal mortgage-related
statutes, only to the extent deemed appropriate
to advance FinCENs mission, strategic goals, and
policies. Op. Cit. 1, Final Rule, 8152.
14Op. Cit. 1, 8151.
15 Some individuals covered by the SAFE Act defi-
nition of loan originator, pursuant to 12 U.S.C.
5102(3)(A)(ii), would not be covered by the AML
Program.
16FinCENs proposed definition of loan or
finance company has been revised to exclude
any Federal or state agency or authority admin-
istering mortgage or housing assistance, fraud
prevention or foreclosure prevention programs.
17See Advisory to Financial Institutions on
Filing Suspicious Activity Reports Regarding Home
Equity Conversion Mortgage Fraud Schemes, FIN-
2010-A005, 04/27/11; Guidance to Financial
Institutions on Filing Suspicious Activity Reports
regarding Loan Modification/Foreclosure Rescue
Scams, FIN-2009-A001, 04/06/09.
18This report is required by law, pursuant to
authority contained in the following statutes.
Board of Governors of the Federal Reserve System:
12 U.S.C. 324, 334, 61 1a, 1844(b) and (c), 3105(c)
(2) and 3106(a). Federal Deposit Insurance
Corporation: 12 U.S.C. 93a, 1818, 1881-84, 3401-
22. Office of the Comptroller of the Currency: 12
U.S.C. 93a, 1818, 1881-84, 3401-22. Office of Thrift
Supervision: 12 U.S.C. 1463 and 1464. National
Credit Union Administration: 12 U.S.C. 1766(a),
1786(q). Financial Crimes Enforcement Network:
31 U.S.C. 5318)(g).
19For a copy of SAR Form TD F 90-22.47, visit
FINCEN.gov/forms/files/f9022-47_sar-di.pdf.
20See 75 FR 63545, 10/15/10.
21See 76 FR 57799, 09/16/11. Paper SARs may
be filed at this time through the Detroit
Computing Center, P.O. Box 33980, Detroit, Ml
48232-0980.
22See 31 U.S.C. 5318(g)(3).
23Such limitation on liability is granted to the
full extent provided by 31 U.S.C. 5318(g)(3).
24See 31 U.S.C. 5318(g)(2).
25In declining a request for SAR information,
an RMLO may cite the FinCEN rule itself as well as
31 U.S.C. 5318(g)(2)(A)(i) in its defense for not pro-
viding information contained in or even admit-
ting the very existence of the SAR.
26Title II of the Bank Secrecy Act as determined
by regulation or in guidance.
27Idem.
28Including a request pursuant to 31 CFR 1.11.
29See United States Code: Subchapter II,
Chapter 53, Title 31.
30Op. Cit. 1, Final Rule, Subpart C-Reports
Required To Be Made by Loan or Finance
Companies.
31Public Law 91508, as amended; codified at
12 U.S.C. 1829b, 12 U.S.C. 19511959, and 31
U.S.C. 53115314, 53165332.
32See 31 CFR 1010.810(a).
33See 31 CFR 1010.810(b)(8).
34See Subpart E of 31 CFR Part 1010. Also
Mortgage Loan Fraud Update (SARs April 1-June
30, 2010), December 2010; Commercial Real
Estate Financing Fraud (SARs by Depository
Institutions, Jan. 1, 2007 to Dec. 31, 2010) March
2011; Advisory: Activities Potentially Related to
Commercial Real Estate Fraud (March 30, 2011).
National Mortgage Professional Magazine
recognizes the support of those Mortgage
Professionals who have stepped up to pay tribute
to the men and women who have fought to
preserve freedom for our great country.
We will be featuring these Mortgage Professionals in
our Mortgage Heroes feature in National Mortgage
Professional Magazine.
We want to hear from you if you:
#Make signifcant donations to any veteran's organizations
#Hosts or sponsors events recognizing and paying tribute
to veterans
#Provides support for the families of veterans
#Any other noteworthy assistance to help improve the
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To be considered for Mortgage Heroes, visit
NMPMag.com/mortgageheroes.
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you. We are offering you all the benefts of partnering with an estab-
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Corporation is a nationwide FHA Direct Lender with a 16 year long
reputation of excellence.
YOUR SUCCESS IS OUR SUCCESS!
For more information contact THOMAS R. SIRICO, Vice
President of Business Development at (917) 923-1472 or email
at tom.sirico@usmortgage.com.
We look forward to sharing our services with you!
(800) LOANS-15
www.usmortgage.com
Retail Branch
#1 USDA RD lender in multiple states with strong FHA/VA/CONV
product lines as well. Don't be held hostage by a captive branch
arrangement. Bank it or broker it. Have a business name/identity
you don't want to give up? We allow DBAs (subject to state rules).
Polaris Home Funding Corp.
616-667-9000
timeforachange@polarishfc.com
www.polarishfc.com/timeforachange
Reach affluent and creditworthy consumers who are in-market and
ready to transact. Bankrate is a consumer direct Web site, NOT a
lead aggregator. Qualified leads for every sized budget, and pay
only for performance. No set up fees! No contracts! No risk!
Founded in 2005, Best Rate Referrals has grown into one of the
fastest growing marketing firms in the nation. By combining new
technology with traditional direct marketing methods that produce
profitable results.
Best Rate Referrals is the direct marketing leader in the mortgage
and banking industry.
Mortgage Direct Mail & List Services
Mortgage Live Transfers
Mortgage Internet Leads
Mobile Marketing
Best Rate Referrals
The Leading Direct Marketing Company
for Mortgage Professionals
800-811-1402 www.bestratereferrals.com
Wholesale/FHA
Icon Residential, a wholly owned subsidiary of Grand Bank N.A.,
is one of the nations leading Conforming, Jumbo, FHA and VA
wholesale lenders. Our strength, success and longevity is
derived from delivering customers service that exceeds our
valued business partners expectations. With deep industry
knowledge, financial stability and innovative technology we
provide the solutions for our business partners to fund loans
while avoiding risk.
Direct Access to Underwriters
Competitive Pricing
Innovative Technology
Paperless Solution
Bank Funding
Icon Residential Lenders
(888) 247-4207
www.iconwholesale.com
Wholesale/Residential
Arizona Nevada Texas
California New Mexico Utah
Colorado Oregon Washington
88 Kearny Street, 3rd Floor
San Francisco, CA 94108
Phone: (415) 632-5150 Fax: (925) 226-1938
www.bayeq.com
CBC National Bank is one of the nations fastest growing
wholesale lenders offering Conventional, FHA, VA, and USDA.
The most important aspect of being a leader in todays market is
the ability to build and maintain a meaningful relationship with
each customer. We understand that these meaningful relation-
ships coupled with competitive pricing and efficient technology
are the pillars of todays lending environment.
We are now hiring Account Executives in AL, TN, KY, VA, & MD.
Contact Stu Ehrlich in our HR department at
sehrlich@cbcnationalbank.com for further details.
Big Enough to MATTERSmall Enough to CARE
CBC National Bank
3010 Royal Boulevard South, Ste. 230
Alpharetta, GA 30022
888-486-4304
Now Wholesale Lending in:
AMX/Land Home Financial ..................800-349-4172
AMX/Land Home Financial Services Wholesale Lending
Division - Great Rates, Great Programs, Great Service.
Offering fnancing options that work in today's market.
Wholesale/Residential
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Wholesale Reverse Mortgages
Veros Real Estate Solutions is a premier technology leader in the mort-
gage industry and proven leader in enterprise risk management and
collateral valuation services. Veros combines the power of predictive
technology and data analytics for advanced automated solutions.
Veros Real Estate Solutions
2333 North Broadway, Suite 350 Santa Ana, CA 92706
(866) 458-3767
www.veros.com @verosres (Twitter)
Paperless! Quick and Easy!
Top Tier Account Executives
Committed to Wholesale
Operations that Earn Your Business
TMSfunding Wholesale Lending
326 W Main Street Milford, Ct. 06460
888.371.2989 WWW.TMSFUNDING.COM
Your Partner in Success!
We offer competitive pricing and fast turn-times for FHA, VA,
Conventional, and USDA programs without having a retail pres-
ence in the industry. We are a wholesale lender with 22 years of
experience and believe in exceptional service.
Terrace Mortgage
4010 W. Boyscout Blvd., Suite 550
Tampa, FL 33607
866-934-4631 www.terracemortgage.com
For Licensed Mortgage Brokers in NY, NJ, CT, PA and FL
No HUD Approval Required Live Help Desk
Will Provide Training at Our Office or Yours
48 Hour Underwriting - Get Paid Within 48 Hours of Funding
NATIONWIDE Equities
Nationwide Equities Corporation
201-529-1401
www.nwecorp.com
If your ad was here, you would be seen by
191,181 Mortgage Professionals looking for
resources to help them in their business.
The Resource Registry is a directory of lenders (wholesaler or retail that are
recruiting), affiliated services and resources that is seen by more than
191,181 active Professionals.
Call 888-409-9770 ext. 4 to register your company.
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MARCH 2012
Sunday-Thursday, March 11-15
29th Annual Regional Conference of
Mortgage Bankers Associations
Trump Taj Mahal Casino Resort
1000 Boardwalk at Virginia Avenue
Atlantic City, N.J.
For more information, call (732)
596-1619 or visit MBANJ.com.
Wednesday, March 14
Florida Association of Mortgage
Professionals Broward Chapter 2012
Annual Trade Show
Broward County Convention Center
1950 Eisenhower Boulevard
Ft. Lauderdale, Fla.
For more information, call (850)
942-6411 or visit FAMB.org.
Sunday-Tuesday, March 18-20
2012 National Association of
Mortgage Brokers (NAMB) Legislative
& Regulatory Conference
Capitol Skyline Hotel
10 I Street, Southwest
Washington, D.C.
For more information, call (972)
758-1151 or visit
NAMB.org/LegConference.
Wednesday-Friday, March 21-23
National Association of Hispanic Real
Estate Professionals (NAHREP) 2012
Real Estate & Policy Conference
Four Seasons Hotel
2800 Pennsylvania Avenue
Washington, D.C.
For more information, call (858)
922-9046 or visit NAHREP.org.
Monday-Tuesday, March 26-27
National Reverse Mortgage Lenders
Association (NRMLA) 2012 Eastern
Regional Meeting and Reverse
Mortgage Securitization Forum
The Grand Hyatt New York
109 East 42nd Street
at Grand Central Station
New York, N.Y.
For more information, call (202)
939-1760 or visit NRMLAOnline.org.
Thursday, March 29
Maryland Association
of Mortgage Professionals 2011
March Mortgage Madness
Convention
Martins Crosswinds
7400 Greenway Center Drive
Greenbelt, Md.
For information, call (410) 752-6262
or visit MDMtgPros.org.
APRIL 2012
Wednesday-Thursday, April 18-19
2012 National Policy Conference
Hyatt Regency on Capitol Hill
400 New Jersey Avenue Northwest
Washington, D.C.
For more information, call (800)
793-6222 or visit
MortgageBankers.org.
Sunday-Wednesday, April 22-25
2012 National Technology in
Mortgage Banking Conference
& Expo
Arizona Biltmore
2400 East Missouri Avenue
Phoenix
For more information,
call (800) 793-6222 or visit
MortgageBankers.org.
Sunday-Wednesday, April 22-25
2012 National Fraud Issues
Conference
Arizona Biltmore
2400 East Missouri Avenue
Phoenix
For more information,
call (800) 793-6222 or visit
MortgageBankers.org.
MAY 2012
Sunday-Wednesday, May 6-9
2012 National Secondary Market
Conference & Expo
New York Marriott Marquis
1535 Broadway
New York, N.Y.
For more information,
call (800) 793-6222 or visit
MortgageBankers.org.
To submit your entry for inclusion in the National Mortgage Professional
Calendar of Events, please e-mail the details of your event, along with
contact information, to newsroom@nmpmediacorp.com.
Friday-Wednesday, May 18-23
2012 Mortgage Bankers
Association of Georgia
Education Forum & Expo
Sandestin Hilton Golf Resort & Spa
4000 South Sandestin Boulevard
Destin, Fla.
For more information,
call (478) 743-8612
or visit MBAG.org.
Sunday-Wednesday,
May 20-23
2012 Commercial/Multifamily
Servicing & Technology
Conference
Hilton Anatole
2201 North Stemmons Freeway
Dallas
For more information,
call (800) 793-6222 or visit
MortgageBankers.org.
Sunday-Wednesday, May 20-23
2012 Legal Issues/Regulatory
Compliance Conference
La Quinta Resort & Club
49-499 Eisenhower Drive
La Quinta, Calif.
For more information,
call (800) 793-6222 or visit
MortgageBankers.org.
JUNE 2012
Sunday-Wednesday, June 3-6
Mortgage Bankers Associations
2012 Chairmans Conference
The Breakers
1 South County Road
Palm Beach, Fla.
For more information,
call (800) 793-6222 or visit
MortgageBankers.org.
JULY 2012
Wednesday-Saturday,
July 11-14
Florida Association of Mortgage
Professionals (FAMP)
2012 Convention & Trade Show
Stay on Track
The Grand Hyatt Tampa Bay
2900 Bayport Drive
Tampa, Fla.
For more information,
call (850) 942-6411 or visit
FAMB.org.
SEPTEMBER 2012
Monday-Wednesday,
September 10-12
2012 American Mortgage
Conference
Raleigh Marriott Crabtree Valley
4500 Marriott Drive
Raleigh, N.C.
For more information,
call (919) 781-7979 or visit
NCBankers.org.
OCTOBER 2012
Sunday-Wednesday,
October 21-24
Mortgage Bankers Association
99th Annual Convention
& Expo
The Hyatt Regency
151 East Wacker Drive
Chicago
For more information,
call (800) 793-6222
or visit MortgageBankers.org.
NATIONAL MORTGAGE PROFESSIONAL
calendar
OF EVENTS
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The BEST Branc h Sol ut i on, Peri od.
Nat i onwi de FHA Lender
This information is provided to assist business professionals and is not an advertisement extended to the consumer,
as dened by Section 226.2 of Regulation Z. Freedom Mortgage corporate ofce is located at: 907 Pleasant Valley Ave.
Suite 3, Mount Laurel, NJ 08054. Lender NMLS I D: 2767. Licensed by the NJ Department of Banking and Insurance,
License #9100861. All Rights Reserved.
EOE
www.Fmbranch.com
800.220.9498
Info@Fmbranch.com
I Prioritize purchase u/w times by contingency or closing dates
I Provide touch points throughout the process to ensure on time closings
I Encourage direct access to all underwriters, internal processors, closers & your
Account Executive
I Order your appraisal online without submitting the credit package no delay
I Offer diverse line:
At CBC National Bank we:
Conventional loans up to 97% LTV
Agency High Balance
FHA loans down to 640
VA loans down to 640
(100% LTV/105% CLTV)
USDA loans