Is Compliance Complicated? Here are a few tips to help!

Tip #1: We have recently seen more loans exceed the maximum points and fees test. When locking your loans, please pay particular attention to the following when locking the loan as lender paid compensation:

• If your comp plan is 2.75% and you have a lower loan amount, GMFS recommends locking the loan “fees in”.
• If your comp plan is 2.75%, locking a loan with no more than 2 discount points is advised, as the maximum bona fide points that can be excluded from the points and fees test is 2.0%.
• If the loan is a purchase money transaction with seller credits, please let us know upfront so we can itemize those credits to prevent your loan from exceeding the points and fees test.

Tip #2: When Crediting the $750.00 customer retention credit, we ask that all clients disclose the fee in this manner. Every credit should be labeled “Customer Retention Credit.”  Program details. 

Tip #3: Please don’t forget to disclose mortgage insurance! This is very important. Mortgage insurance is a zero tolerance fee and there is not a valid COC to add it after initial disclosures have been issued. This mistake results in thousands of dollars in tolerance cures.

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