National Mortgage Professional Magazine - April 2010

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Value Nation: The Mortgage Meltdown and AppraiserSelection By Charlie W. Elliott Jr., MAI, SRA

Regulatory Compliance Outlook: April 2010EscrowRequirements for Higher-Priced Mortgage Loans By Jonathan Foxx

SAFE Smart Testing, Education and Licensing: The Testin the Bar By Paul Donohue, CRMS

The Secondary Market Overview: Predictions By Dave Hershman

The NAMB Perspective

NMP Mortgage Professional of the Month: Steven A.Milner, President and Chief Executive Officer of MortgageConcepts

FDIC Finds Fair Lending Violations Under ECOA for CreditReporting Fees By Terry W. Clemans

Trend Spotter: Why Tax Knowledge Matters By Gibran Nicholas

Half-Empty? Half-Full By Donald E. Fader, CRMS

Ask Tommy: Your QC Expert By Tommy A. Duncan, CMT

Forward on Reverse: Reverse Mortgages for First-TimeHomebuyers By Atare E. Agbamu, CRMS

A View From the C-Suite: Redefining Going Green By David Lykken

Will the Mortgage Industry Witness Another Influx of Non-Traditional Lenders By Ed F. Wallace Jr., Ph.D.

Going Green and Stamping Out Fraud By Tommy A. Duncan, CMT

Paperless Lending Offers Fraud Risk Mitigation By Sharon Matthews

Paperless or Just Less Paper? By Erik Wind

Pieces of the P.I.e: Paper, Imaged and e-Documents By Greg Smith

Eight Reasons Why E-mail Marketing Works for MortgageBrokers By Wendy Lowe

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April 2010Volume 2 Number 4

1220 Wantagh Avenue Wantagh, NY 11793-2202Phone: (516) 409-5555 / (888) 409-9770

Fax: (516) 409-4600Web site: www.nationalmortgageprofessional.com

Mortgage PROFESSIONALN A T I O N A L

M A G A Z I N E

Your source for the latest on originations, settlement, and servicing

STAFFEric C. Peck

Editor-in-Chief(516) 409-5555, ext. 312

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Andrew T. BermanExecutive Vice President(516) 409-5555, ext. 333

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Domenica TrafficandaArt Director

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Karen KrizmanSenior National Account Executive

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Jennifer MoellerBilling Coordinator

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ADVERTISINGTo receive any information regarding advertising rates,deadlines and requirements, please contact SeniorNational Account Executive Karen Krizman at (516) 409-5555, ext. 326 or e-mail [email protected].

ARTICLE SUBMISSIONS/PRESS RELEASESTo submit any material, including articles and pressreleases, please contact Editor-in-Chief Eric C. Peck at(516) 409-5555, ext. 312 or e-mail [email protected]. The deadline for submissions is the first of themonth prior to the target issue.

SUBSCRIPTIONSTo receive subscription information, please call (516)409-5555, ext. 301; e-mail [email protected] visit www.nationalmortgageprofessional.com. Anysubscription changes may be made to the attention ofCirculation via fax to (516) 409-4600.

Statements of fact and opinion in National MortgageProfessional Magazine are the responsibility of theauthors alone and do not imply an opinion on thepart of NMP Media Corp. National MortgageProfessional Magazine reserves the right to edit, rejectand/or postpone the publication of any articles, infor-mation or data.

National Mortgage Professional Magazine is published monthly by NMP Media Corp.

Copyright 2010 NMP Media Corp.

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A Message From NMP Media Corp. Executive Vice President Andrew T. Berman

Going green? Paperless?So when we thought of doing a special section on Going Green/Paperless, I assumedwed be reporting on some great companies that have gone green and have experi-enced great savings and an increase in productivity. Instead, I have been hearing night-marish scenarios about $50 million-per-month mortgage operations spending inupwards of five figures on paper and related dead-tree technology expenses. I am evenhearing stories about so-called paperless offices, where specific employees insist onprinting out PDFs so they can view their documents offline. However, most compa-nies are trying to make the push towards paperless. It seems that the benefits, such as

savings, the ability to market yourself as a green company, increased productivity, better control overyour processes and document management, far outweigh the negatives.

In our Going Green/Paperless section, you will learn from Tommy Duncan, CMT that going paperlessis of great concern when it comes to fraud detection. The loss of wet signatures leaves room for would-be fraudsters to take advantage of the system. Sharon Matthews shows how lenders are using technolo-gy to analyze the data behind what you and I see on the screen to mitigate fraud. In the contribution byErik Wind, he shares with us how many are finding that while paperless might not be possible, thereare a great many benefits of just less paper. The section wraps up with a piece from Greg Smith of Xeroxwhere he shares information on his companys P.I.e (Paper, imaged documents and electronic documents)program.

What business does a print publication like National MortgageProfessional Magazine have featuring a section on going green? Arewe hypocritical?Lets face the facts, while we are all getting more and more news from the Internet, the magazine formatstill provides a medium that educates us about areas that we didnt know we should be in the knowabout. This is evident by our increasing paid subscriber base (thats you and thank you!). Furthermore,more than 70 percent of our readers choose to read our publication online (yes, even though 25 percentof those choose to print it out).

On the road again My first conference of this year was the recent Regional Conference of Mortgage Bankers Associations inAtlantic City, N.J. and all I can say is, Wow! What a turnout! More than 1,400 attendees were on hand toshare in this magical experience. I am not talking about the plastic-fabricated magic that we were sur-rounded by at The Trump Taj Mahal, but an organic magic created from the collaboration and networkinggoing on with the industrys best. The mortgage industry has filtered out the garbage and is left with theproverbial cream of the industrys crop. And they were all there at The Trump Taj. Heres a shocker newwholesale lenders! Overall, it was a great event that gave the feeling of a renewed sense of pride aboutbeing a mortgage professional in 2010.

I hope you enjoy yet another edition of National Mortgage Professional Magazine. We are on the vergeof the one-year anniversary of this undertaking, and so far, have received nothing short of rave reviews.The proof is in you, our readership, who turns to us for the latest in industry news, through both ourmonthly print edition and our daily updated Web site, NationalMortgageProfessional.com. Im happy toreport that our blogger community is growing, as is the number of registered users on our site each day.

Again, I thank you for your support of our publication over the past year, and I raise my glass to toastmany more years to come.

Sincerely,

Andrew T. Berman, Executive Vice PresidentNMP Media Corp.

National Credit Reporting Association Inc.125 East Lake Street, Suite 200 Bloomingdale, IL 60108

Phone #: (630) 539-1525 Fax #: (630) 539-1526Web site: www.ncrainc.org

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The National Association of Mortgage Brokers

7900 Westpark Drive, Suite T-309 McLean, VA 22102Phone: (703) 342-5900 Fax: (703) 342-5905

Web site: www.namb.org

PresidentJim Pair, CMCMortgage Associates Corpus Christi6262 Weber Road, Suite 208Corpus Christi, TX 78413(361) [email protected]

President-ElectWilliam Howe, CMC, CRMSHowe Mortgage Corporation9414 E. San Salvador Drive, #236Scottsdale, AZ 85258(602) [email protected]

Vice PresidentMichael DAlonzo, CMCCreative Mortgage Group1126 Horsham Road, Suite DMaple Glen, PA 19002(215) [email protected]

SecretaryGinny Ferguson, CMCHeritage Valley Mortgage Inc.5700 Stoneridge Mall Road, Suite 150Pleasanton, CA 94588(925) [email protected]

TreasurerDon Frommeyer, CRMSAmtrust Mortgage Funding Inc.200 Medical Drive, Suite DCarmel, IN 46032(317) [email protected]

Joe CamarenaThe Mortgage Source10120 Southwest Nimbus Avenue, Suite C-7Portland, OR 97223(503) 443-1060 [email protected]

John Councilman, CMC, CRMSAMC Mortgage Corporation2613 Fallston Road Fallston, MD 21047(410) 557-6400 [email protected]

Olga KucerakCrown Lending8700 Crown Hill Boulevard, Suite 804 San Antonio, TX 78209(210) 828-3384 [email protected]

Walt ScottExcalibur Financial Inc.175 Strafford Avenue, Suite 1 Wayne, PA 19087(215) 669-3273 [email protected]

Don StarksD.C. Starks Mortgage Associates Inc.141 South Main Street Bourbonnais, IL 60914(815) 935-0710 [email protected]

Marty FlynnPresident(925) 831-3520, ext. [email protected]

Tom ConwellVice President(248) [email protected]

Daphne LargeTreasurer(901) [email protected]

William BowerDirector(800) [email protected]

Mike BrownDirector(800) [email protected]

Susan CataldoDirector(404) 303-8656, ext. [email protected]

Nancy FedichDirector(908) 813-8555, ext. [email protected]

Sanford (Sandy) LubinDirector(805) [email protected]

Judy RyanDirector(800) 929-3400, ext. [email protected]

Tom SwiderDirector(856) 787-9005, ext. [email protected]

Donald J. UngerDirector(303) 670-7993, ext. [email protected]

NCRA StaffTerry ClemansExecutive Director(630) [email protected]

Jan GerberOfficeManager/Membership Services(630) [email protected]

PresidentLiz Roberts-Fajardo, GML(702) [email protected]

President-ElectGary Tumbiolo, CMI(919) [email protected]

Senior Vice PresidentSharon Patrick, MML, CMI(386) [email protected]

Vice President/Northwestern RegionJill M. Kinsman(206) [email protected]

Vice President/Western RegionTim Courtney(760) [email protected]

Vice President/Central RegionCandace Smith, CMI(512) [email protected]

Vice President/Greater NortheastRegionColleen-Therese McKeever, CMI(646) [email protected]

Vice President/Southeastern RegionJessica Edmonston(919) [email protected]

SecretaryLaurie Abisher, GML, CMI(661) [email protected]

TreasurerKay Talley, MML(919) [email protected]

ParliamentarianHulene Bridgman-Works(972) [email protected]

NAMB Board of Directors

National Association of ProfessionalMortgage Women

P.O. Box 140218 Irving, TX 75014-0218Phone: (800) 827-3034 Fax: (469) 524-5121

Web site: www.napmw.org

Officers

Directors 2010 Board of Directors

National Board of Directors

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The Mortgage Meltdown andAppraiser Selection

Within the past couple of years, we haveexperienced a complete meltdown ofour economy, the mortgage industryand our banking system. As a result, wehave witnessed wholesale changes in theway appraisals are purchased. Mortgagebrokers, loan officers and anyone elsewith a financial interest in a transactionare unable to purchase appraisals.

This requirement hasbeen imposed by FannieMae, Freddie Mac andthe Federal HousingAdministration (FHA) onall loans, either pur-chased or made by them.In todays market, thatrepresents most, if notall, of the mortgage loanmarket. In the past, WallStreet was buying loans,but that practice hasground to a halt due toall of the bad loans. As aresult, federally-backedmortgages are practicallythe only game in town.

There has been muchcomplaining by mortgagebrokers, loan officers and even Realtors andappraisers over this newpractice. Unfortunately, the changecomes at a time when loan volumes arein the gutter, property values are in thetank, home foreclosures are at an all-time high, and the overall economy ison the ropes. When we combine all ofthese factors, it makes the origination ofa marginal loan difficult, to say theleast. Some say that these marginalloans should not be made; others saythat these circumstances make apprais-ers less accountable.

Many have complained about thisnew process and the new rules. Is itlikely to change, or are we stuck with asystem where lenders and Realtors arenot going to be able to select and orcommunicate with appraisers in thefuture?

Before determining the answer, wemust consider the fact that our entirefinancial system was in danger of goingdown the tubes as a result of the mort-gage meltdown. Practically everyone inour society was damaged in one way oranother by the collapse of the system,and, like it or not, most of the problemstemmed from toxic mortgages. Due to

this catastrophic failureof the system, our politi-cal leadership cannot andwill not take this problemlightly. While there is suf-ficient blame to goaround, the consensus ofopinion is that inflatedappraisals were largely toblame for the crack in themonetary system. It willnot be easy going forwardfor regulators and politi-cians to relax appraisalprocurement rules set inplace by Fannie, Freddieand the FHA. Specifically,what may we expect inthis regard?

For starters, there islikely to be a tighteningof the mortgage system inmonths to come like we

have never seen. Interest rates aregoing to increase, mortgage qualifica-tion requirements will continue to berigid for many would-be borrowers,and appraisal scrutiny will be tougher,not lighter.

The powers that be are currently say-ing that the root of the problem isappraiser pressure being imposed bythose selecting appraisers, purchasingappraisals and reviewing appraisalsand that these are the very peoplestanding to gain by collecting fees fromthe closing of the loan transaction.Further, appraisers, in some cases, areaccused of collecting fees on appraisals,which they inflate just to insure that

continued on page 7continued on page 6

While there is sufficient blame to goaround, the consensus

of opinion is thatinflated appraisals

were largely to blamefor the crack in themonetary system.

By Charlie W. Elliott Jr., MAI, SRAColumbia Law Schoolstudy finds: Federal actionresulted in more defaultsand riskier lending

Federal action to exempt nationalbanks from state anti-predatory lend-ing laws resulted in more defaults andriskier lending compared to otherbanks, found a study funded by theNational State Attorneys GeneralProgram at Columbia Law School. Atthe same time, the study found anti-predatory lending laws enacted bysome to protect consumers from abu-sive and unfair mortgage practicessaved many people from losing theirhomes to foreclosure.

The implications of these results areextraordinarily important, said JamesTierney, director of the National StateAttorneys General Program. Thisreport proves that that vigorous stateconsumer protection laws make a posi-tive difference for consumers through-out the country. The federal govern-ment must respect that clear fact.

The study, titled The PreemptionEffect: The Impact of FederalPreemption of State Anti-PredatoryLending Laws on the Foreclosure Crisis,was conducted by researchers at theUNC Center for Community Capital. Itfound foreclosures and risky lendingincreased as a direct result of the pre-emption order enacted by the Office ofthe Comptroller of the Currency (OCC)in 2004.

Our research confirms that stateconsumer protection laws worked, butthat when one group of lenders ishanded a regulatory free pass, they aregoing to take advantage of it, saidCenter for Community Capital DirectorRoberto G. Quercia. In this scenario,unfortunately, we see preemption shift-ing the activities of federally insuredbanks to riskier activities than theywould otherwise have pursued.

The research findings are the resultof two companion reports that offer thefirst comprehensive look at loan quali-ty and performance following the fed-eral preemption of state laws in stateswith and without strong anti-predatorylending laws.

This research shows the need for

strong, consistent mortgage laws inNorth Carolina and across the country,said North Carolina Attorney GeneralRoy Cooper, who wrote the nations firstcomprehensive state law combatingpredatory lending as a state senator.While our laws kept more homeownersfrom risky loans than other states, ourcommunities are still suffering from toomany foreclosures. Washington needs tolet states set high standards and holdunfair lenders accountable.

The order exempted nationally char-tered banks and their subsidiaries frommost state laws regulating mortgagelending, including stricter laws that hadbeen passed by some states to curbabusive, predatory mortgage lending.

The center analyzed data from 2.5million mortgages before and after fed-eral preemption in states with andwithout anti-predatory lending laws.The mortgages examined were issuedfrom 2002-2006, and represent about30 percent of U.S. mortgages rated sub-prime or Alt-A and about five percent ofall U.S. mortgages during the period.

We believe these results providestrong support for policy proposals thatwill prevent regulatory loopholes, sothat borrowers can rely on the full pro-tection that state laws afford them,said Quercia.For more information, visitwww.ccc.unc.edu/preemptioneffect.

California tops Interthinxmortgage fraud riskindex for Q4 of 2009

Interthinx has released its quarterlyMortgage Fraud Risk Report, coveringdata collected during the fourth quar-ter of 2009. The report includes ananalysis of national mortgage fraudand indices for the four most commontypes of mortgage fraud. It indicatesthat most fraud types are on the rise,with increases in the risk index foroccupancy fraud, employment/incomefraud, and property valuation. The lat-ter is up more than 100 percent fromtwo years ago.

The study finds that California nowhas the highest mortgage fraud risk,

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In July 2008, the Federal Reserve Board approved a final rule, which amendsRegulation Z (the Truth-in-Lending Act) and was adopted under theHomeownership and Equity Protection Act (HOEPA). The new rule addressed anddefined higher-priced mortgage loans (HPML), a new category of mortgageloans, while also providing additional protection to consumers.1 Most require-ments of the rule were to be implemented on Oct. 1, 2009.

Four key protections were provided to consumers:

Borrower Ability: Lenders must take a borrowers ability to repay the loan fromincome and assets other than the homes value into account when making the loan.

Verification of Income/Assets: Lenders must verify the income and assetsthey rely upon to determine repayment ability.

Prepayment Penalty: Prepayment penalties are prohibited if the mortgagepayments can change in the first four years; and, for other higher-priced loans,a prepayment penalty period cannot last for more than two years.

Escrow Accounts: Lenders must establish escrow accounts for property taxesand homeowners insurance for all first-lien mortgage loans.

HPML calculationDetermining if a loan is an HPML origination requires a calculation using a spe-cific survey-based index, as follows:

The rules definition of an HPML origination captures virtually all loans in thesub-prime market, but generally excludes loans in the prime market.

Effective date: April 1, 2010The escrow account requirement must be implemented on April 1, 2010. Thisdeferral of the requirement until April 1, 2010 was given in order to provide orig-inators sufficient time to set up escrow account procedures. Lenders must becomefamiliar with federal and state escrow account requirements.

Implementation dates Effective April 1, 2010, the lender will be required to set up an escrow account

for residential real estate-secured HPMLs.

Effective Oct. 1, 2010, the lender will be required to set up an escrow account fornon-real estate-secured (principal dwelling) HPMLs (i.e., manufactured homes).

Escrow requirementsEffective with the dates indicated above for the respective types of HPMLs, the

Escrow Requirements forHigher-Priced Mortgage Loans

lender must set up an escrow account for loans subject to the HPML escrowrequirements. Escrow mandates only affect first lien transactions. (Exception:Escrow is not required for a condominium, if the condominium association main-tains a master policy that covers the individual condominium units for items suchas homeowners insurance and property taxes.)

The HPML originations escrow account must be set up to pay items such asproperty taxes and premiums for mortgage-related insurance (such as homeown-ers insurance) that the lender has required.

RESPA requirementsEscrow requirements under federal law, such as under the Real Estate SettlementProcedures Act (RESPA), must be implemented. RESPA provides detailed escrow require-ments, escrow account calculation methodologies, and also some model forms.2

Some salient RESPA requirements for escrow accounts Disclosure of the initial escrow account statement at the time an escrow

account is established. Annual escrow account disclosure. Certain limitations on how the escrow account is funded, ensuring that the

account is not overfunded with the borrowers money.

State requirementsState law places further requirements on escrow accounts. Some states exceedRESPAs mandates in limiting the amount of the escrow cushion. Additionally, statelaw might require the lender to pay interest on the amount in the escrow account.

Submit your questions Do you have a regulatory compliance issue that youd like to see addressed in theRegulatory Compliance Outlook Column? If so, e-mail your issue or concern toJonathan Foxx at [email protected].

Jonathan Foxx, former chief compliance officer for two of the countrys top publicly-traded residential mortgage loan originators, is the president and managing directorof Lenders Compliance Group, a mortgage risk management firm devoted to provid-ing regulatory compliance advice and counsel to the mortgage industry. He may becontacted at (516) 442-3456 or by e-mail at [email protected].

Footnotes1Compliance with the new rules, other than the escrow requirement, is manda-tory for all applications received on or after Oct. 1, 2009. The escrow requirementhas an effective date of April 1, 2010 for site-built homes, and Oct. 1, 2010 formanufactured homes2See 24 CFR 3500.17, RESPAs Escrow Requirements section, for further informa-tion on RESPA escrow requirements. The U.S. Department of Housing & UrbanDevelopment (HUD) publishes a number of Public Guidance Documents that illus-trate the proper way to fund and manage an escrow account.

Survey-Based IndexThe rule establishes a category of higher-priced mortgage loans secured by aconsumers principal dwelling, defined as a first lien mortgage that has anannual percentage rate (APR) that is 1.5 percentage points or more above theaverage prime offer rate, or, if the loan is a subordinate lien loan, 3.5 per-centage points above this Survey-Based Index.

The average prime offer rate index is based on a survey published byFreddie Mac, and can be found on Freddie Macs website at the following tab:Weekly Primary Mortgage Market Survey.

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CSBS and AARMR reachsettlement agreementwith CitiFinancial

The Conferenceof State BankSupervisors (CSBS)and the AmericanAssociation ofR e s i d e n t i a l

Mortgage Regulators (AARMR) haveannounced a 35-state settlement, in whichCitiFinancial agreed to remit a $1.25 millionpenalty. The agreement between statemortgage regulators and CitiFinancialwas executed following an examinationconducted by the Massachusetts Divisionof Banks to determine compliance withstate and federal consumer protectionlaws. The examination found thatCitiFinancial had failed to report 91,127residential mortgage loans to the federalgovernment as required by the HomeMortgage Disclosure Act (HMDA). The res-idential mortgage loans that were omit-ted from CitiFinancials HMDA LoanApplication Register were originatedbetween 2004 and 2007. The failure toreport the loans was apparently causedby an internal systems error atCitiFinancial that went undetected untilthe Massachusetts Division of Banksexamination.

HMDA remains the primary tool weutilize to ensure compliance with fairlending laws and regulations, saidSteven L. Antonakes, MassachusettsCommissioner of Banks. By failing toaccurately report all required transac-tions, CitiFinancial hampered our abilityto complete that assessment. Therefore,this agreement will ensure that the sys-tems, training, and appropriate over-sight and controls are in place to avoid asimilar occurrence in the future.

Major terms of the agreementinclude:

CitiFinancial already resubmittingcorrected and complete HMDAreports to the Federal ReserveSystem for the years 2004-2007;

CitiFinancial engaging an independ-ent consultant to conduct a thor-ough fair lending review to ensurethe data from the previously unre-ported 91,127 mortgage transac-tions does not in any way demon-strate a pattern or practice of dis-criminatory lending practices;

CitiFinancial will thoroughly reviewand substantially modify its internalcontrol procedures to ensure allreportable HMDA transactions areaccurately compiled and reported; and

CitiFinancial will remit a penaltytotaling $1.25 million to the 35 statesthat are party to this agreement.

This settlement highlights the valueof state enforcement of federal con-sumer protection laws, said Mark

with an index value of 222. Nevada,which had the highest index for theprevious five consecutive quarters,drops to second place with an index of220, and is closely followed by Arizonawith an index of 211. Florida remainsin fourth place with an index of 179,while Colorado is in fifth place at 153.

The occupancy fraud risk indexrose 16 percent since last quarterthe first significant increase in theindex since the fourth quarter of2006. The magnitude of the quarter-on-quarter increase suggests thatoccupancy fraud risk will be a seri-ous issue going forward, as continu-ing price declines and get-rich-quickschemes lure investors back into themarket and as builders face continu-ing difficulty in moving unsoldinventory.

Despite a slight (four percent) quar-ter-on-quarter decrease, the propertyvaluation fraud risk index is up 40 per-cent over last year and up more than100 percent from two years ago.Schemes involving short sales, realestate-owned (REO) inventories, whole-sale flipping, and refinancing by bor-rowers whose equity has beenimpaired by falling real estate valuescontinue to drive this index.

Interthinx analysts expect lendersto focus more closely on fraud risk mit-igation as they work to emerge fromthe downturn. This will help guardagainst the potential for fraud as alarge number of adjustable rate mort-gage loansespecially option ARMswith negative amortization featuresreset between now and the first quar-ter of 2012.

Lenders have expressed theirappreciation for our investment to pro-vide a more detailed analysis of thedata weve been collecting, said KevinCoop, president of Interthinx. Ourmost recent report provides data thatlenders can use to anticipate and pre-pare for trends that will impact theirrisk mitigation strategies. The reportcan ultimately make them more suc-cessful at identifying fraud before loansare funded.

The Interthinx Mortgage Fraud RiskReport is fast becoming the primarysource of information about fraud riskin the mortgage industry, and withgood reason, added Mike Zwerner,senior vice president for Interthinx.Interthinx has the depth of data toidentify, categorize, and help lenderseffectively mitigate mortgage fraudrisk. Using our own proprietary dataalong with outside public dataresources, the quarterly report revealswhere mortgage fraud risk is occurring,where it is migrating, and howschemes are changing. Were pleasedthat more institutions are relying onour reports.For more information, visitwww.interthinx.com.

news flash continued from page 4

The Test is the BarIt made no sense to me. When I heard you could take the national test before sit-

ting for the 20 hours of pre-license education (PE), Im thinking what a regulatoryboondoggle. How could they draft up something this illogical? Then I learned it was-nt a mistake; this disconnect was quite purposeful.

Rich Madison, the NMLS Director of Education Programs explained to our educa-tion working group that, it is not pre-testing education, it is pre-licensing education.He added, there is no connection between the education requirements of the SAFEAct and the national test. This seemed curious to me. I knew it needed further ex-ploration. What were they up to?

Education Minimized, the Test Emphasized The twenty hours of required PE is designed to satisfy a bare minimum of MLO

competency requirements. The twenty hours only requires 8 hours of core education;the remaining twelve hours is elective. Each state is allowed to use as many of theseelective hours for any state education it deems appropriate. It began to dawn on methat education, though important, was not the focus of MLO competency validation.

Clearly, the bar of entry is the national test. It supplies the true capability meas-urement for MLOs. The national test is designed to be both broad and deep. The testcovers 146 different areas of study. The test questions are interpretive in nature, re-quiring a firm conceptual understanding of these subjects in order to score well. Thetest is the bar and it is set quite high.

Test Break DownThe national test component entails 100 questions that include 10 un-scored questions

used for developmental purposes. The questions are all multiple choice and you will have150 minutes for completion. The test is broken down into the following four categories.

Federal mortgage related laws (35%) General mortgage knowledge (25%) Mortgage loan origination activities (25%) Ethics (15%)

My concern for brand new students of the mortgage industry is the MLO activitiessection, which covers more that 62 separate subjects. A new person with no contex-tual understanding of the business will naturally struggle in this area.

My concern for an experienced mortgage veteran is the federal law and the ethics sec-tions, which explore 14 different federal laws and consumer protections. How long hasit been since you studied the HOEPA prohibitions? Do you understand the difference be-tween providing ECOA based adverse action vs. FCRA based adverse action notices?

A SAFE Smart ApproachDont think you are going to waltz into this test and ace it. The questions are filled

with double negatives and trip words designed to throw you off. This is first a read-ing test and second, a knowledge bar.

The industrys new bar of entry is the 100-question national test. My SAFE Smartadvice to you is take a test specific 20-hour PE course first, then get a good exam preptool and buckle down to study.

Paul Donohue, CRMS is a 23-year industry professional and founder of Abacus MortgageTraining and Education. Paul served on two NMLS working groups, establishing the newnational education protocols. Go to AbacusMortgageTraining.com to find out more aboutyour obligations for testing, education and licensure, or call (888) 341-7767.

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Tax Return Verication (4506 tax transcript donein less than 24 hours in most cases)

Flood Certication Report Automated Valuation Model (AVM) Reports Verication of Employment (VOE)



By using PCSs VOE service, I was able to move thecost onto the HUD1 and virtually get the VOEs done atno cost to my company

PCSs high level of customer service ensures that myloans close on TIME!

the loan closes and of continuing to getbusiness from the people who hiredthem. Even when it is not true, the per-ception is there, and, because of this, itwill be hard for regulators and legisla-tors to allow business as usual.

In conclusion, it is not fair to any ofthe self-respecting professionals con-cerned, including lenders, appraisersand Realtors, to be subjected to thetemptation to commit fraud or to bepositioned where the perception wouldbe that they are acting in a less-than-pro-fessional manner. Neither is it fair to thetaxpayer for there to be a door for indus-try participants to practice business insuch a way that the taxpayer is on thehook to cover the cost of avoidable badloans. Nor is it fair to the borrower to payfor an appraisal and a loan whereby heor she is exposed to foreclosure due tounscrupulous business practices.

Finally, it is not fair to the regulators,who must enforce rules, to be put in aposition where there is opportunity forfraud on their watch. Given all of the rea-sons above, stricter rules are not only like-ly to be implemented, but they are alsonecessary to protect a system from whichwe all benefit from as professionals.

value nation continued from page 4If these rules eliminate a few bad

apples, so be it. In the past, the badapples had the advantage of siphoningoff business from those who follow therules. Under todays new system, theplaying field is level and the ethical pro-fessionals will enjoy the business pro-vided by our industry, without beingput in a position of their having to sub-scribe to the same underhanded tacticsof the less-than-ethical practitioners inorder to earn a living.

Yes, stricter rules will come at aprice, but it is worth the investment. Itis a necessary cost of doing businessand it will serve to protect all of societyfrom the type of catastrophic eventsthat we have experienced and are expe-riencing. Going forward, appraisersmust continue to be insulated from thepressure of those having a financialinterest in loan transactions.

Charlie W. Elliott Jr., MAI, SRA, is presi-dent of Elliott & Company Appraisers, anational real estate appraisal company.He can be reached at (800) 854-5889, e-mail [email protected] or visit hiscompanys Web site, www.appraisalsany-where.com.

So whats the answer? Be knowl-edgeable. That is why we teach the sec-ondary markets as part of the CertifiedMortgage Advisor Program. Hedge yourbets. Make sure your business model isdiversified. Putting all your eggs in onebasket is never a good idea.

I asked Eric Holloman, our secondaryexpert and the chief executive officer ofRateLink, about his view of the future.He says that it is important to watch thenational news. For example, many loanofficers are trying to figure out whytheir loans are getting underwritten todeath right now when the crisis shouldbe easing. Yet, if you read about FannieMae repurchases and what lenders aregoing through in this regard, it makesperfect sense. If the loan is not perfect,

when something goes wrong, it is beingthrown back in their face. It is not onlyabout rates, it is about how someonewill have to navigate the process toachieve the American dream of home-ownership.

Dave Hershman is a leading author forthe mortgage industry with eight booksand several hundred articles to his credit.He is also head of OriginationProMortgage School and a top industryspeaker. Daves Certified Mortgage AdvisorProgram can be found at www.webina-rs.originationpro.com. If you would liketo stay ahead of what is happening in themarkets, visit ratelink.originationpro.comfor a free trial or e-mail [email protected].

One word that says it all. We are con-stantly trying to predict the future.When you go on the street and meetwith real estate agents, they ask you,What do you think will happen withrates? When you set up your businessplan, it is all about know what will hap-pen within several areas of the mar-kets, such as refinances versus purchas-es. Consider this prediction releasedrecently:

Refinances in 2010 will be down 52percent and purchase mortgage vol-ume will be down five percent from2009, according to the latest projec-tions from iEmergent, a Des Moines,Iowa-based market research firm.

Others have predicted rising ratesthis year and cite the following factors:

The Federal Reserve Board with-drawing from the mortgage-backedsecurities (MBS) markets

The Fed also starting to tightenmonetary policy as the economyrecovers. The Fed has alreadyincreased the Discount Rate as asymbolic gesture.

The markets getting spooked bylarge government deficits which willfuel the threat of inflation. As thegovernment borrows more, thisforces rates up because of increasedsupply in the bond markets.

Here is the problem. We cannot pre-dict the future. One event tomorrowcould change everything. That is why Ihave never been a believer in technicalcharts. It is the fundamentals which areimportant. Fundamentally, we areheading into an economic recovery,and if all goes well, rates will rise, butnot drastically. If the economy gets toostrong too quickly or steps back into arecession, all bets are off. These factorsare so entwined that we never knowhow they will come out. For example, ifthe recovery is stronger, that meanshigher rates because of the risk of infla-tion. But a stronger recovery alsomeans that the deficit will start todiminish more quickly and that couldtranslate into lower rates. Finally, if the

recovery is stronger, people will havemore jobs and buy more houses, whichmakes it more likely that housing pricesare not falling and mortgages become afavored investment again. Confusedyet?

Your job as an originator is to stay ontop of what is happening. Today, thatmeans every hour. You need not beable to predict the future. However, youshould know what factors are in playand what events are on the horizon thatcould impact the markets. For example,if you dont know that the employmentreport is being released the first Fridayof every month, you cannot stay ontop of the markets. I get a text mes-sage on my phone from RateLink(www.RateLink.com) that providesupcoming events, as well as changesin the markets.

Once again, predictions are not onlyabout rates. The economy itself pro-vides much suspense for us. For exam-ple, I am surprised at how many origi-nators are starting loan modificationefforts now. I have often said that loanmods might be a great service from oneto four years. It is now almost two yearsafter I started saying that. Some see pre-dictions of five million foreclosures tocome on a market and predict that loanmods will be going strong five yearsfrom now. But the fact is that a strongereconomy, along with low rates and a taxcredit, could shorten this period to 18months. And that would be good for allof us. Do I know the answer? No.

However, I do know the factors in playthat could change the time frame sig-nificantly. Even the value of the dollarbecomes important because if the dol-lar stays weak, this increases demandfrom foreign investors. Basically,American real estate is on sale. And thesale is really great if you are from acountry with a strong currency.

Predictions

Refinances in 2010 will be down52 percent and purchase mortgagevolume will be down five percentfrom 2009, according to the latestprojections from iEmergent, a Des

Moines, Iowa-based marketresearch firm.

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NAMB Setting the Bar onProfessionalism in theMortgage IndustryA Message From NAMB President Jim Pair, CMC

If you did not attend the 2010 National Association of MortgageBrokers Legislative & Regulatory Conference in February, you missedone of the very best conferences NAMB has sponsored that I haveever attended. Every panel covered a topic that was crucial to ourindustry, and the panelists were experts on the topics presented.There was plenty of time for the attendees to address the panelists

with questions that were answered in a straightforward manner. The highlight ofthe event was the luncheon where FederalHousing Administration (FHA) CommissionerDavid H. Stevens spoke to us. He provided us withsome important information, including discussingthe important role the mortgage broker plays inthe mortgage distribution channel.

Many of the attendees came up to me orexpressed in e-mails, the same impressions I hadof the conference. Much of the credit for such asuccessful conference must be given to Jon Otto,NAMBs director of government affairs. Jon andthe staff of NAMB were responsible for the organ-ization of the conference, selecting the topics forthe various panels, arranging for the panelists tospeak and locking up Commissioner Stevens as our luncheon speaker. Manythanks to Jon and his team for a conference that was well-planned, well-coordi-nated, and as I said previously, one that was very informational on all the currentissues impacting our industry.

The Legislative & Regulatory Conference is just one of the many benefits for NAMBmembers. It is the only conference NAMB holds that is restricted to NAMB membersonly. As a member attending the conference, you are receiving information beforeanyone else, as evidenced by Commissioner Stevens announcement at our luncheon.

In the current market environment, there are two more very important bene-fits for NAMB members.

The Lending Integrity Seal of Approval sets you apartfrom all the other loan originators. As a NAMB memberlicensed under the SAFE Act and certified by your state asso-ciation, you are qualified to use the Seal. By using the Seal,you have pledged to abide by a strict Code of Ethics,Professional Standards and Best Lending Practices, and aNAMB grievance review process.

The Seal should be used in all in your advertising, busi-ness cards, stationery, etc. You can go to www.lendingin-

tegrity.org and learn how to download the Seal for use in radio ads, print ads,press releases and letters to your customers and prospects. There is even a videothat you can use in presentations to Realtors, business groups or other groups thattells the story of the Lending Integrity Seal of Approval. The Seal will truly set youapart from loan originators who do not qualify.

Besides qualifying for the Lending Integrity Seal of Approval, a NAMB membermay go one step further and obtain a designation. NAMB offers the CertifiedMortgage Consultant (CMC), the Certified Residential Mortgage Specialist (CRMS)and the General Mortgage Associate (GMA) designations. Anyone receiving their

designation has distinguished themselves from other originators, even thosequalified to use the Lending Integrity Seal of Approval. Obtaining a NAMB-certi-fied designation means you have passed a rigorous test, have experience in theindustry and met the necessary qualifying points to earn the designation. Go towww.namb.org and click on the Certification tab and learn more about how youcan achieve the highest level of professionalism and really set yourself apart fromall other loan originators.

These are only a few of the benefits available to you when you become a NAMBmember. To learn more on how to become a member, go to www.namb.org andclick on the Membership button, scroll down to Join Now and click to join. Youwill find all the information needed to join the only association working to pro-tect our industry and the consumer.

Jim Pair, CMC is with Mortgage Associates Corpus Christi and is president of the NationalAssociation of Mortgage Brokers. He may be reached by e-mail at [email protected].

Certification? Certainly!How Do You Know?A Message From NAMB CertificationsCommittee Chair Pava J. Leyrer, CMC, CRMS

I am sure everyone is buzzing with licensing requirements that allloan originators for non-depositories have to complete in the nexttwo to four months. Whether we agree or not, it is the law and wemust comply with it to be licensed. The reason I bring this up isbecause of standards and a basic thought process.

Do you know just the basics to do your job, or are you above thecurve and make it part of your profession to excel? To be licensed, you have therequired minimum in each state and must follow those. To receive a certification,it is now your choice and opportunity to excel above the basics to a higher leveland set yourself apart from everyone else.

How do you know though which to choose? I have personally seen differentofferings for distinction and there are even more coming out now for varioustopics. When I was reviewing those options and trying to decide, I looked at whatcredentials and knowledge was needed. As I reviewed the NAMB certificationsand the goals set for them, I realized that this was more than just a pay forpaper certification. I was not buying the right to have the CMC (CertifiedMortgage Consultant) or CRMS (Certified Residential Mortgage Specialist) titles. Ihad to work for them and know my profession and then prove it through a testto gain those honors.

I have always been passionate about my industry and profession. It has beenan area that the experienced train and share with those wanting to break into ourindustry. I believe that those of us still fighting for what we believe in and whatwe have to offer our valued customers and communities, can also recognize theimportance of defining our knowledge and taking the next step to becoming cer-tified and maintaining these certifications.

Take time today to know where you want to stand in this industry and howbecoming NAMB-certified can benefit you and your business.

Pava J. Leyrer, CMC, CRMS, is president and owner of Heritage National MortgageCorporation in Grandville, Mich., and Certifications Committee chair for theNational Association of Mortgage Brokers. She may be reached by phone at (616)534-4993 or e-mail [email protected].

For more information on the National Association of Mortgage Brokers, visit www.namb.org.

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PCS appraisal management services allowedme to create a virtual firewall between the loanofficers and the appraisers, yet still maintain a high level of quality, fast, and accurate appraisals

Bank of America is a strong propo-nent of the home retention goals of theMaking Home Affordable program, andwe have placed HAMP at the center ofour broad-based mortgage modifica-tion efforts, said Schakett. Recently,we became the first servicer to formal-ly agree to participate in the HAMP sec-ond-lien modification program, furtherdemonstrating our commitment toputting as many financially strugglinghomeowners as possible into a moreaffordable and sustainable situation.

Bank of America is also a leadinglender-participant in the HomeAffordable Refinance Program (HARP).Nearly 152,000 Bank of America cus-tomers have benefitted through theenhanced loan-to-value and stream-lined provisions of that prong of theMaking Home Affordable initiative. Intotal, Bank of America helped morethan 1.1 million customers refinancetheir home in 2009.For more information, visit www.banko-famerica.com.

NAHB poll showsAmericans firmly support governmenthousing initiatives

Americans remain strong-ly committed to federalsupport for homebuyers,according to a recentsurvey of U.S. house-holds conducted by the

National Association of Home Builders(NAHB) by RT Strategies. Roughly 68 per-cent of those polled said the governmentshould continue to support housing,and 65 percent believe the govern-ment should be doing more to keepfamilies from losing their homes toforeclosure.

RT Strategies, is a non-partisan pub-lic opinion polling firm based inWashington, D.C. RT Strategies inter-viewed a representative sample of1,000 adults nationwide by telephoneusing live interviewers on Jan. 29-31,2010. The sample included 170 inter-views with respondents from cell-phone-only households.

Among those polled, some keygroups said the government shouldcontinue to play a vital role in main-taining a healthy housing market. Forexample, 78 percent of all potentialhomebuyers, including 81 percent ofrenters intending to buy a home in thenear future, said the governmentshould continue to support housing.

Roughly 65 percent of homeownerssaid the government also needs to domore to keep families from losing theirhomes. Support for more foreclosureprotection was not confined merely tocurrent homeowners. Among renters,84 percent said the government needsto do more to helped strapped borrow-ers. This issue is particularly importantto women, with 71 percent supporting

Pearce, president of AARMR and ChiefDeputy Commissioner of the NorthCarolina Office of Commissioner ofBanks. State regulators supplementexisting federal efforts and help ensureconsumer protections are rigorouslyenforced. This settlement demon-strates the ability of state regulators towork together effectively to addressour systemic compliance concerns witha large national lender.

State regulators have significantlyenhanced multistate cooperation inrecent years through projects such asthe development and launch of theCSBS/AARMR Nationwide MortgageLicensing System (NMLS) and the cre-ation of the Multi-State MortgageCommittee to provide seamless super-vision of mortgage companies operat-ing in more than one state.For more information, visitwww.csbs.org or www.aarmr.org.

Bank of America com-pletes 12,700 permanentHAMP modifications

Bank of Americahas realized sig-nificant gainsmodifying mort-

gages through the governments HomeAffordable Modification Program(HAMP). At the reporting deadline for theU.S. Department of Treasurys February2009 monthly servicer progress report,Bank of America had quadrupled thenumber of completed modifications forits customers since the previous monthsreport.

More than 12,700 Bank of Americacustomers now have a permanentHome Affordable modification, upfrom nearly 3,200 a month earlier.Another 13,700 permanent modifica-tions are pending, meaning finalmodified loan terms have beenapproved and documents have beensent for the customers signatures,which will be their final step to acompleted modification.

In the past month, our concertedcustomer outreach initiative has drivena substantial increase in the rate ofconversions from trial to permanentmodifications, as we anticipated in ourrecent reports of HAMP progress, saidJack Schakett, credit loss mitigationstrategies executive for Bank ofAmerica Home Loans. These resultsare attributable to the resourcesincluding expansion of our defaultmanagement staffing to more than15,000and focus we have placed insupport of this and other homeowner-ship retention programs.

Since January 2008, Bank ofAmerica has helped 700,000 customerswith a loan modification through ourown programs and with trial and com-pleted modifications through theAdministrations Home AffordableModification Program (HAMP).

news flash continued from page 6greater foreclosure protection, com-pared to 58 percent of men.

Keeping families in their homes isalso particularly important to first-timehomebuyers, as 78 percent of youngadults under age 30 support greaterforeclosure protection. And 69 percentof adults who are 30-44, the prime agerange for move-up buyers, said theysupport more foreclosure protection.

Overall, roughly two-in-three respon-dents said they own their home. Amongrenters, about two-in-three intend tobuy a home in the near future. In addi-tion, 15 percent of current home own-ers intend to buy a home in the nearfuture.

The poll asked respondents for their viewsregarding the Worker, Homeownership, andBusiness Assistance Act of 2009 thatextended a tax credit of up to $8,000 forqualified first-time homebuyers purchas-ing a principal residence. The legislation,which was signed into law by PresidentObama in November 2009, also author-ized a tax credit of up to $6,500 for quali-fied repeat homebuyers.

Overall, eight percent of those sur-veyed said they intend to take advan-tage of that credit, while another 24percent who might have been interest-ed in using the tax credit said they can-not afford to purchase a home at thistime. Of the 33 percent of respondentswho said they are planning to buy ahome (both renters and current homeowners), roughly 17 percent said theyintend to use the tax credit.

Financial concerns continue to bethe greatest barrier to growth in thehousing market. Among renters nation-wide who aspire to own their ownhome, 39 percent simply dont have themoney to buy a home at this time, andanother 20 percent said the primaryobstacle is that they feel they cannotqualify for a loan. Larger economicissues also play a role, as 18 percentsaid that job security is the greatestobstacle they face in trying to buy ahome.

Weakness in the housing marketitself may be blocking some home own-ers who would like to buy a new home,as 29 percent of current homeownerssaid their greatest obstacle to purchas-ing another home is their inability tosell their current home. Beyond that,

among current home owners whoaspire to buy a new home, seven per-cent feel trapped by a mortgage thatexceeds the value of their currenthome, 14 percent fear that the value ofa new home might fall after they makethe investment, and 13 percent sayhome prices are just too high to allowthem to buy a new home at this time.

Forty percent of respondents saidtheir home is their most valuableinvestment, twice the number who citeany other single investment401kaccounts, savings accounts and CDs,stocks and bonds, or mutual fundsastheir leading family investment.For more information, visit www.nahb.com.

FICO finds disturbingtrends in consumer credit behavior

FICO, a provider ofanalytics and deci-sion management

technology, has announced new find-ings uncovered in the latest analysisoffered by its subscription service forbusinesses, FICO Score Trends.Reversing a long historic trend, mort-gage default risk for consumers withhigh FICO scores now exceeds theircredit card default risk, even thoughmost credit cards are unsecured creditand mortgages are secured by realestate. The company observed a paral-lel rise in mortgage delinquencies forhigher-scoring U.S. consumers.

According to the analysis in FICOScore Trends, recent repayment behav-ior across the financial services industryhas shifted significantly from historicaltrends. In 2008-2009, bankcardaccounts were just 1.6 times more like-ly to become 90 days delinquent thanwere mortgage loans. By comparison,in 2005 bankcard accounts were morethan three times more likely to become90 days delinquent. And for borrowersscoring high on the FICO scores 300-850score range, the level of repayment riskactually has become greater for realestate loans than for bankcards. In2009, 0.3 percent of consumers withFICO scores between 760-789 defaultedon real estate loans, compared to 0.1percent who defaulted on bankcards.

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om Each month, National MortgageProfessional Magazine will focus on oneof the industrys top players in ourMortgage Professional of the Monthfeature. Our readers are encouraged tocontact us by e-mail at [email protected] for consideration in beingfeatured in a future MortgageProfessional of the Month column.

This month, we had a chance to chatwith Steven A. Milner, president andchief executive officer of US MortgageCorporation d/b/a Mortgage Concepts, acompany he founded in 1994. Milnerhas been a retail loan officer since 1981.

He was born in Los Angeles, and atthe age of 12, moved to the East Coastand his family settled in New York. Theymoved around the state a bit, movingfrom the Bronx, and then on to Baysideand eventually, out to Long Island, set-tling in Brentwood.

He graduated from Brentwood HighSchool in 1967 and went to college atFarmingdale State College, where hefocused on engineering. Steven eventual-ly switched over to the field of educa-tion, where he became a school teacherin the Brentwood School District on LongIsland.

In 1986, he formedMortgages Unlimited Inc., aNew York State-registered mort-gage broker. In September1994, Mortgage Conceptsbecame operational, and in1997, became a New YorkState-licensed mortgage banker.Steven is actively involved withthe day-to-day operations ofeach department in the compa-ny, and is in constant commu-nication with each departmentmanager who represents ateam of dedicated, highly-skilled mortgage banking pro-fessionals. Currently, MortgageConcepts is a licensed mort-gage banker and is an FHA/VA

Direct Lender, in 18 states and growing,providing retail mortgage lending andreverse mortgage lending.

How did you first get startedin the mortgage industry?As the Vietnam War began to escalate,the federal government was givingdeferments to school teachers, so in1969, I changed my major from engi-neering to education. I enrolled in theteaching program at Stony BrookUniversity and finished my degreethere. Ironically enough, I did my stu-dent teaching at the elementary schooloriginally attended in Brentwood, N.Y.

I was in the education field for about18 years, provisionally certified toteach kindergarten through sixthgrade. In 1973, I got married, and atthe time, I was making $25,000 as aschool teacher and my wife was alsomaking around $25,000 annually as ateacher. In 1978, my son, Scott, wasborn and we immediately went frommaking $50,000 a year to $25,000 ayear, as my wife became a stay-at-homemom. The single income stream neces-sitated that I start hustling around, con-tinuing to go to school at night and

work part-time jobs, including a bas-ketball coach, intramural coach, foot-ball coach and student council advisor.By 1981, I had tried every part-time jobjust to make a few extra bucks, includ-ing selling Amway products, while con-tinuing my education at CW Post, study-ing school supervision, as my goal wasto become a principal.

That same year, I went to refinancemy home. When we went for the refi,the salesperson who took the applica-tion also happened to be a teacher inthe Huntington School District on LongIsland. I said, Gee if you can do this,I can do this too! I thought it was agood idea to do loans part-time, givingup all my other part-time jobs to focuson just one thing. I asked if I could setup an interview, and the followingweek, came back and sat down to learnwhat it was all about. I was told thatthey did not do any training, and that Iwould have to teach myself the busi-ness. I was given a copy of the FannieMae/Freddie Mac Seller/Servicer Guide,which was about four inches thick, andwas told to go home and read it.

I came back the following week,after reading the guide, and askedexactly what the position entailed. Atthat time, the 1003 was a one-pagedocument, front and back, not fourpages. I figured it seemed pretty easy,as you had to be detail-oriented, whichI was already as a teacher. I said, Showme the money! So, he offered me 125percent commission. I could notbelieve that I was going to be paid $125for originating a $100,000 loan.

What people forget is that the 1003was never designed for a loan officer tocomplete it was designed for theborrower to complete. Its not rocketscience. Unfortunately, we have madeit into rocket science, but it was alwaysdesigned for a borrower to completewith respect to their income, assets,credit, liabilities and so on. To me, it

was just a matter of establishing a rela-tionship with a borrower, interviewingthem and collecting the information.

I decided to give up all of my part-time jobs in 1981-1982 to just focus onmortgages in a part-time capacity. Inlife, we often come to a fork in the roadand must choose which side to take.Sometimes, its the right fork andsometimes its the wrong fork, and inmy case, I know I made the right deci-sion. In deciding to give up all of mypart-time jobs, it created a great finan-cial strain on my family income.

How did you find your new-found interest in the mort-gage arena in the beginning?Being that I didnt recieve any train-ing, I had to approach Realtors, attor-neys, financial planners and account-ants the old-fashioned way and hit thestreets. I did this from 2:30 p.m.-5:00p.m. each day, after I left teaching. Ididnt give up teaching because I hadto still make a living. So I started totake applications and go to school atnight because my objective was still tobecome a principal.

The first 24 applications that I tooknever closed in my first six months. Itwas getting brutal, as I had lost mypart-time income and now was mak-ing nothing in the mortgage field. Iwas actually losing money because Iwas incurring expenses bringing incoffee, bagels and donuts and all thatstuff trying to establish relation-ships with my contacts through net-working.

Steven A. Milner, President and Chief Executive Officer of Mortgage Concepts

To me, its not about makingmillions, its about getting loans

closed the right way, assuringto the best of our ability that

the loan is going to get repaid.

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Learn more about our services by calling, Lorenzo Pugliano, President and CEO at 631-299-2084.www.platinumcreditservices.com

What was it that kept you in afield where you were losingmoney in?Ive always believed that persistenceovercomes resistance, and I knew thatmoney was to be made in the mortgage

marketplace. I just lacked the properdirection due to the absence of train-ing. I vowed, at that point, that if I wereto ever have my own mortgage compa-ny, I would train my salespeople andprovide them some direction. I had atremendous desire to succeed in thisbusiness.

One day in school, I was giving atest and took out some of my mort-gage paperwork. One of the studentsasked if I was into real estate, and hesuggested I meet his father who wasalso in the real estate industry. Mystudents father had an office inQueens, so we set up a meeting anddiscussed some opportunities. Hewas a real estate broker in Floridaand what he wanted to do was sellme properties in Florida. I wasntinterested in that, but he did intro-duce me to his sales manager whowas running the mortgage brokeragedivision. She offered me a 50 percentcommission. I signed on and was

finally starting to close loans. I wouldsolicit real estate agents, attorneysand financial planners, primarily todo purchase money business in theBrentwood, Long Island, N.Y. area Itaught in. I would take applicationsin local libraries, diners or wherever Icould meet clients.

In 1986, I received my doctorate inmathematics and supervision, and wasready to move on to the next step inmy career as a school principal. I wasmaking $45,000 as a teacher and$115,000 selling mortgages.

In those days,we didnt have cellphones, and faxmachines were anovelty. The onlyreal form ofadvanced commu-nication that I hadwas a pager. In myrecorded pagermessage, I saidthat I would return their call in fiveminutes. That became my trademark,to call back within five minutes nomatter where I was. Thats how I endedup developing my business, going fromfive loans per month, to 10 loans, to 15with nothing more than a stack of busi-ness cards and the reputation of work-ing hard, being responsive and deliver-ing on my word.

Did your success in the mort-gage field and the opportuni-

ty you saw to make money inthis field lead you to quitteaching? Yes, I came to yet another fork in theroad, and in 1986, I had the opportuni-ty to open up a mortgage company withtwo other partners in Bayside, N.Y.When I left teaching, I gave up 60 per-cent of my pension. If I had taughtanother two years, I would havereceived my full pension, but I had toevaluate what was right at the time andmade my decision to go full-time intothe mortgage industry.

My two partnersworked the the FiveBoroughs, and Iworked Nassau andSuffolk Counties onLong Island. At anygiven time, I wouldhave $30-$50 inquarters in theglove compartmentof my car and I

knew the location of every pay phoneon Long Island! Cell phones did notexist.

Our primary business was purchasemoney, all Realtor-based. I wouldhand-deliver the commitments to theattorneys, the selling agent, the listingagent, and market myself to everyoneinvolved in the transaction. It became astrictly referral-based business. I didnot know how to do consumer-directtelemarketing or how to buy leads.

We eventually opened up a satellite

office on Long Island in Hauppauge,N.Y. in 1991 and another larger office inBohemia, N.Y. in 1992.

We dissolved that corporation in1994, due to a difference in opinion. Iwanted to become a mortgage bankerand my partners wanted to remainmortgage brokers. We werent process-ing our loans the way mortgage brokersprocessed their loans, as we were usingthe Citibank Mortgage Power Program,the Williamsburg Power Program andGreenPoint. Basically, wed fax the infoover to them and they would do theloan. We were doing 125 loans permonth with one or two employees,making a lot of money with very littleoverhead, but I felt the industry waschanging and that we should becomemortgage bankers.

I formed US Mortgage Corporation in1994, with the intent of opening upand getting my mortgage broker regis-tration approved by Oct. 1, 1994, whichI ultimately did, and during that timeperiod, I developed the logo for USMortgage Corporation or USMC. TheUSMC name looked too much like theUnited States Marine Corps, and I didntthink I was getting the right messageacross, so we made it d/b/a MortgageConcepts. We developed a unique sell-ing proposition, which was HelpingYou Make It Home, the slogan we usedon all of our business cards, Web site,literature, etc.


Mortgage Concepts is doing inthe neighborhood of $30-$35

million per month consistently.

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Why did you want to makethat change from mortgagebroker to mortgage banker?I felt that I needed to control more ofthe process, specifically, the underwrit-ing of the loans. Additionally, I felt thatthe future was in mortgage bankingand not mortgage brokering. We stayeda broker until 1997, and then receivedour banker license in 1988.

I developed a nice tight knit group ofretail referral-based loan officers, dongbusiness exclusively in Nassau andSuffolk Counties, primarily receivingbusiness from the Realtor community.Our business was consistently 90 per-cent purchase money transactions.

I have always worked very hard atthis business, working 16-18 hoursevery day. I have always told my staffthat I am like a Motel 6 I will alwaysleave the light on for you.

I started to see a change around thelast quarter of 2004, a very unusualdrop in originations that had pro-gressed into 2005 that got much worsein 2006. I eat, sleep and breathe thisbusiness.

In 2004, there were no FHA [FederalHousing Administration] loans on LongIsland to speak of because of the highloan amounts, and the loan limits werevery low on FHA loans I had my Mini-Eagle, but did not use it very often.

The one decision I made that savedthe company was that I never put onesub-prime loan on my warehouse line.I could have made a lot more moneylike many other people did, but Iwould rather make less and stay inbusiness.

Ive always had the philosophy thatbigger is not better better is better.I think that philosophy has transcend-ed through everything I do withMortgage Concepts. To me, its notabout making millions, its about get-ting loans closed the right way, assur-ing, to the best of our ability, that theloan is going to get repaid. Wevealways consistently done 80-120 loansper month, with an average size of$400,000 per loan, and keeping theeconomies of scale in place. MortgageConcepts is closing approximately$30-$35 million per month consis-tently.

In 2006, I felt that I had to changemy business model because I saw atremendous decrease in values in theLong Island, N.Y. market, which iswhere we are focused. Values weredecreasing, and it was affecting thepurchase money business. I love what Ido and I felt like I really needed to re-invent Mortgage Concepts, whichrequired that I change from having aone-dimensional business model,which was primarily purchase moneyout of Nassau and Suffolk Counties, to amulti-dimensional mortgage companydoing business in other states.

In changing your model, howdid you attract new salespeople?I changed and expanded my businessmodel and basically applied the J. PaulGetty theory where Id rather have onepercent of 100, than 100 percent of one.To do that, I decided to become licensedin as many states as I possibly could, start-ing in 2007. This way, I could attract sales-people from all of the states we werebecoming licensed in. I felt that I wasstrong on the operational side, from orig-ination through closing. In terms of sales,I had to create an opportunity in differentstates by opening up corporate branches.Many states still allow loan officers towork out of their home, while othersrequire brick and mortarlocations. We are currentlylicensed in 18 states, andhave our FHA and USDA[United States Departmentof Agriculture] approval.

We allow our loan offi-cers to originate fromtheir homes or from theirbrick and mortar offices,but we process andunderwrite all of theloans in our Bohemia,N.Y. headquarters. I can-not allow off-site process-ing and underwriting.Everything has to flowthrough here, and nowwith technology, that goalis much simpler to accom-plish. Currently, we haveapproximately 140 sales-people licensed in 18states, but within just afew weeks from now, we will be licensedin 20 states. My goal by the end of theyear is to be licensed in 35-30 states andnot to expand without control. You haveto be able to control the quality of theorigination and maintain integrity ofthe files which is challenging with a 10percent unemployment rate.

Our loan officers do a compilation ofeverything, including purchase moneyand refinances on a referral basis, orthey do lead-based where they pur-chase their own leads, but we do not doany direct response marketing. Directresponse marketing can create anunderlying pressure from the loan offi-cer through the underwriter to closeloans, to meet the economies of scaleand to meet the budgetary require-ments of running a mortgage company.Lets face it, if you are spending$300,000-$500,000 per month onadvertising, you have to close a lot ofloans. That means you are going to beputting a lot of pressure on salespeopleand on management to essentiallyclose loans without any regard for thewillingness of the borrower to repay,and I think that philosophy has causedthe demise of many of the larger mort-gage companies.

What is Mortgage Conceptscurrent minimum FICO score?Its 620 across the board, but its proba-bly going to go to 640. I think that youare going to see that scores under 640will have some very serious perform-ance issues. There is a higher degree ofa borrowers unwillingness to pay, so weare probably going to have to migrateand have our own credit overlays andtransition to scores of 640.

One of my objectives is to obtainGinnie Mae approval by the end of theyear. Ive seen companies get GinnieMae approval and use it to their disad-vantage. They adapted a sort of kid inthe candy store type mentality. Certaincompanies take their Ginnie Maeapproval and use it to do loans theyknow are not going to perform. Itinevitably catches up with you whenyou approve loans that should not beapproved.

Do you have anyparticular businessphilosophy you liketo impart uponyour salespeople?Ive always felt that theneeds of the corporationexceed the needs of theindividual. The needsand longevity of the cor-poration are more impor-tant than what a Realtorneeds, a loan officerneeds and what a bor-rower needs, becausewithout the corporation,none of those aforemen-tioned entities have any-thing. We do not need tosit here and talk about allthe mortgage companiesthat are left with nothingbut some desks and

paperclips in their drawers. My objec-tive has always been to stay in business,and that means that if we are going tostick around in the mortgage bankingbusiness, we have to make good loans.That is what we offer salespeople allover the country the fact that we will bein business. They have a future with usat Mortgage Concepts. We are not goingto say yes to every loan, but you willmake a good living.

What do you consider thenext big thing for the mortgage industry as a wholethat mortgage professionalswill need to embrace?Being an ex-educator, I have alwaysbeen a proponent of education. I thinkit is imperative that any loan officerwho speaks to a borrower must complywith state-specific registration, educa-tion and testing requirements. I thinkthat is huge, and it says a lot to anyfuture employer. When we get out ofhigh school and we go to college, wepay to go to college and generally workharder while at college. There shouldbe no difference when it comes to themortgage business. If you are going toenter this profession, then you should

know the profession. You have to beable to look somebody in the eye anddeliver what you say you are going todeliver. I think this requires a change inattitude, and a change in behavior withrespect to where business is comingfrom.

Over the last four or five years, I wasnever, quite frankly, a proponent of theconsumer-direct model, because I feltthere was a level of integrity missing.Loan officers have to get that back andhave to re-establish that. I still feel thatas values begin to stabilize, there willbe tremendous opportunity for loanofficers to obtain business the old-fash-ioned way of walking into the offices ofRealtors, attorneys, financial plannersand accountants, and be their purchasemoney source for their borrowers.

I think that the loan officer who istechnologically advanced and educa-tionally advanced will capture morebusiness going forward and that goeswith the infrastructure of mortgagecompanies as well.

On the origination side, MortgageConcepts is 100 percent paperless. I thinkit really enhances our ability to be moreefficient. I think loan officers need to dothat. With education comes knowledgeand confidence, and I think that is theprimary focus I would like to see loanofficers take. LOs cannot have thisdumping ground mentality that theyhad years ago. If the borrower fogged amirror, they got a mortgage. That nolonger works and it is going to take somebehavior modification over the next fewyears to change that mentality.

How do you use technologyto make sure that process ofvetting a loan does not slowdown the process? What kindof technology does MortgageConcepts have in place tomake sure the process runssmoothly?Your first step is to communicate andeducate your loan officers on your phi-losophy of doing business, and that iswhere behavior modification comes intoplay. They have to understand that weare partners, and are all in this together.As a loan officer, you have a responsibili-ty to listen and provide a service for yourborrowers to the best of your ability.

Step two is from an internal infrastruc-ture standpoint. We use many differentlayers of services that are provided to uson a technological basis regarding theintegrity of the file from evaluating


The needs and longevity of thecorporation are more impor-

tant than what a Realtor needs,a loan officer needs and what aborrower needs because with-out the corporation, none of

those aforementioned entitieshave anything.

nmp mortgage professional continued from page 11

I eat, sleep andbreathe this busi-

ness working 16-18 hours each day.Im like the Motel

6, I will alwaysleave the light on

for you.

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one case created a $32 difference whenthe fees are passed along to the con-sumer, as a settlement services charge atclosing. That fee difference discriminatesagainst the unmarried co-applicantsbased on marital status and is a violationof the ECOA sections cited above.

From a processes perspective,unmarried co-applicants were alsofound by the FDIC examiners to havesome discriminatory issues. One of the

banks the FDIC noted onthe violations was due tothe requirement thatunmarried co-applicantscomplete separate appli-cations, while marriedco-applicants completeda single application. Thisrequirement is a violationof the same standardsregardless of marital sta-tus provisions of theabove sections.

While correcting thepricing issue for ECOA compliance is fair-ly simple: Make sure that whatever theprice a joint credit report is, the cost oftwo individual credit reports equals thatsame amount. Correcting the applicationprocesses issue is something more com-plex. The National Credit ReportingAgency Inc. (NCRA) has discovered thatsome loan origination systems (LOS) haverequirements that split unmarried co-applicants into two separate applicationsfor processing. This varies from system tosystem, and can even also vary pendingthe current address status of the co-applicants. On some systems, if the co-applicants are currently residing at thesame address, they can be entered on asingle application. However, this is moreof a problem when the co-applicants areresiding at different locations at the timeof the loan application. Some LOS do nothave the ability to enter differentaddresses for co-applicants on a singleapplication, regardless of marital status.This can also be problematic with thetransfer of that data from the workflowof the LOS, to the mortgage credit report-ing agency, to the national credit reposi-tories and back with the credit report. Ofcourse, with several different systems

In March, some New England areabanks received notice from the FederalDeposit Insurance Corporation (FDIC)New York Division of Supervision andConsumer Protection that a recentexamination found potential violationsof the Equal Credit Opportunity Act(ECOA) for Fair Lending violations per-taining to the fees and processesimposed upon consumers for the creditreports related to their mortgage loans.

The credit reportingpractices in question havebeen found to violateECOA Section 202.4 (a) ofRegulation B which pro-hibits a creditor from dis-criminating against anapplicant in any aspect ofthe credit transaction onthe basis of marital sta-tus. Further, Section202.2(m) of Regulation Bdefines a credit transac-tion broadly to includeevery aspect of an applicants dealingswith a creditor regarding an applicationfor credit or an existing extension ofcredit (including, but not limited to,information requirements; investiga-tion procedures; standards of credit-worthiness; terms of credit; furnishingof credit information; revocation; alter-ation or termination of credit; and col-lection procedures). The preliminaryfindings continue with citations fromSection 202.6(b)(8) of Regulation Bwhich requires that a creditor shallevaluate married and unmarried appli-cants by the same standards; and inevaluating joint applicants, a creditorshall not treat applicants differentlybased on the existence, absences orlikelihood of a marital relationshipbetween the parties.

So, why are these credit reportingpractices setting off so many alarms?

From the fee structure perspective, itis the difference in the price of the cred-it reports that some banks have negoti-ated with their credit reporting agenciesthat give a price reduction to co-appli-cants that are traditional joint creditfiles (typically a husband and wife)which is not available to non-traditionalco-applicants that are unmarried. Thisdiscounted credit report fee, which in

FDIC Finds Fair LendingViolations Under ECOA for Credit Report Fees

By Terry W. Clemans


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National Mortgage Professional Magazine - April 2010

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Transcript of National Mortgage Professional Magazine - April 2010