The FFIEC calculator will calculate rate spreads for both fixed and variable rate products. Directions for using the calculator can be found by clicking on the calculator’s Web page.
new to market
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Setting the rate9 The relevant date to use to determine the APOR for a comparable transaction is the date on which the loan’s interest rate is set by the lender for the final time before closing: 1.If an interest rate is set pursuant to a “lock-in” agreement between the lender and the borrower, then the date on which the agreement fixes the interest rate is the date the rate was set and confirmed by lender. 2. If a rate is reset after a lock-in agreement is executed (for example, because the borrower exercises a float-down option or the agreement expires), then the relevant date is the date the rate is reset by lender for the final time before closing. 3. If no lock-in agreement is executed, then the relevant date is the date on which the lender sets the rate for the final time before closing.
matter where it appears in documentation and no matter what line of business it appears in. It’s a ‘map once, deploy many’ philosophy that enabled us to bring mortgage, consumer and commercial lending to market in just over a year of development time.” For more information, visit www.integraonline.com or www.compliancesystems.com.
MRG offers a browser-based system for the preparation and delivery of compliant document packages, electronic disclosures, loan modifications and other services for mortgage lenders, banks and credit unions nationwide. MRG’s products are guaranteed to be in compliance with the most recent legislative and regulatory changes. For more information, visit www.mrgdocs.com.
MRG launches dashboard for originators HOEPA reporting (Homeownership and Equity Visionet releases and servicers Protection Act) M R G D o c u m e n t repurchase and claims Although a new test for HPML was added to HOEPA as a result of the above-outTechnologies (MRG), management suite lined 2008 changes to Regulation Z, lenders will still establish HOEPA status using an APR and points and fees trigger tests. The fees trigger may cause a loan to fall under HOEPA even if the loan’s rate spread would not be reportable. If the loan exceeds either the APR or points and fees triggers, its HOEPA status must be reported on the HMDA Loan Application Register (LAR) using Code 1 (for loans that a lender originates or purchases that are subject to HOEPA restrictions because the APR or the points and fees on the loan exceed the applicable HOEPA triggers). The difference in the HOEPA test and the rate spread test is the metric used to determine HOEPA status and rate spread calculations. As currently required by Regulation Z, HOEPA will continue to require lenders to use the H.15 statistical release table as the source of Treasury yields, while the rate spread approach uses new tables developed by the Board titled “Average Prime Offer Rate-Fixed” and “Average Prime Offer Rate-Adjustable.”10
Submit your questions … Do you have a regulatory compliance issue that you’d like to see addressed in the Regulatory Compliance Outlook Column? If so, e-mail your issue or concern to Jonathan Foxx at jfoxx@lenderscompliancegroup.com. Jonathan Foxx, former chief compliance officer for two of the country’s top publicly-traded residential mortgage loan originators, is the president and managing 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.
FNC unveils property decision valuation tool
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NOVEMBER 2009
FNC Inc. has launched Collateral Investigator, a multifunctional data and analytics solution developed to provide accurate information about the
KENTUCKY MORTGAGE PROFESSIONAL MAGAZINE
1-Regulation C, 12 CFR 203, Final Rule. 2-Source: St Louis Fed: Regulation C Amendments, Transition Rules. 3-Use the rate lock-in date on the loan to first determine the applicable Treasury yield date. Then correlate that date to the 15th of the preceding month (1) if the rate is set between the 1st and 14th of the month or (2) the 15th of the current month if the rate is set on or after the 15th day. After determining the appropriate Treasury yield date, identify the Treasury yield of a comparable maturity from the “Treasury Securities of Comparable Maturity under Regulation C” table. Compare this Treasury yield to the APR at consummation to calculate the rate spread. If the difference between the APR and the Treasury yield is equal to or greater than three percentage points for first liens, or five percentage points for subordinate liens, report the amount of the rate spread. If the difference is less than the applicable threshold, “NA” will be reported in the rate spread field on the HMDA LAR. 4-Op. cit. 2, Rate Spread. 5-Average prime offer rates are annual percentage rates derived from average interest rates, points and other loan pricing terms offered to borrowers by a representative sample of lenders for mortgage loans that have low-risk pricing characteristics. To obtain average prime offer rates, the Board uses a survey that meets these criteria and also provides pricing terms for at least two types of variable-rate transactions and at least two types of non-variable-rate transactions. An example of such a survey is the Freddie Mac Primary Mortgage Market Survey (PMMS). 6-The “average prime offer rate” is survey-based, and, for the foreseeable future, the Federal Reserve Board plans to use a specific survey currently published by Freddie Mac. The PMMS can be found at www.freddiemac.com/dlink/html/PMMS/display/PMMSOutputYr.jsp. 7-www.ffiec.gov/ratespread/newcalc.aspx. 8-Op. cit. 2, Pricing Data. 9-Appendix A to Part 203 (HMDA, Regulation C), I, G, 1 (2). 10-Op. cit. 7.
Visionet Systems has announced the availability of the newest versions of its VisiRepurchase and VisiClaims products. VisiRepurchase is used to manage residential mortgage repurchase demands by investors. VisiClaims, is used to initiate claims in line with the parameters of various seller’s agreements. These software solutions increase the number of successful appeals and claims. They improve efficiency by automating routine operations, leveraging skills, enforcing rules and reducing costs for the risk operations department. VisiRepurchase, originally launched in July of 2006, was designed to manage 400 to 500 demands per month, the average repurchase volume at the largest U.S. banks at that time. However, the recent meltdown has pushed repurchase activity to an unprecedented level. In many cases 5,000 to 10,000 repurchases and claims per month are the norm at the top U.S. banks. Visionet redesigned VisiRepurchase and VisiClaims to manage these larger loan volumes and hundreds of additional users. The solutions can support bulk repurchases, appeals, demands, claims and data updates. Both products utilize state-of-the-art workflow and rules engine technologies and can be quickly reconfigured to satisfy changing business and regulatory needs. Visionet has added several standard reports that provide up-to-date portfolio risk information to the chief risk officer or chief financial officer, so regulatory requirements are met in a timely fashion. These reports provide real-time visibility of repurchase and claims pipelines and assist in the enforcement of deadlines. A central portal is provided to connect disparate risk management organs within the bank. For more information, visit www.visionetsystems.com/mortgage.htm.
www.NationalMortgageProfessional.com
Footnotes
a provider of mortgage technologies to banks, credit unions and other lenders, has launched a dashboard feature to MIRACLE Online, its electronic document preparation and compliance software, so that mortgage originators and servicers can have detailed visibility into the process workflow of their loan originations, refinances and modifications. Based on workflow criteria provided by the lender or servicer, the dashboard provides real-time visibility to the flow of document creation or the forward movement of multiple events affecting the status of loans. The dashboard and workflow concept gives lenders control of a situation and the ability to automate certain steps that are otherwise handled manually by an individual or team of people. “We created the dashboard feature so lenders can find out exactly at what stage their loans are within the workflow at any given point in time and can share this information with their staff or technology partners,” said Laura LaRaia, an attorney and director of customer service at MRG. “For example, the dashboard reports let the lender or servicer know if loans are flowing at an optimal speed through the process or the reports may show that there is a backlog of loans that needs to be addressed by adding more staff to an area to handle the slowdown.” The process workflow is a customizable, rules-driven engine with automatic notifications, conditional data analysis, reporting and historical audit tracking. Users can configure the visibility of individual windows of information, known as portlets, in the dashboard and can retain each user’s preferences as to the location and order of these portlets to provide a personal dashboard for each user based on his or her role within the organization. Dashboard features include drill-down functionality, role-based security, userlevel filtering and private labeling. Workflow features include parallel processing, automated events created with lender or service definitions, data collection screens for manual events and customizable event duration thresholds with notifications.
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