“getting my loan into compliance” · the loan is withdrawn or denied with in those 3 days then...

11
“GETTING MY LOAN INTO COMPLIANCE” Following this tutorial will ensure that you are always in COMPLIANCE! IN COMPLIANCE + FUNDED = PAYCHECK STEP 1 – ENTER YOUR LOAN INTO ENCOMPASS USING THE METHODS FOUND IN THE ENCOMPASS TUTORIAL. http://www.topflitefinancial.com/BackOffice/Download/encompass-newhire.pdf STEP 2 – FOLLOW RESPA’s 3 DAY RULE. You are required to send your client (per RESPA) Initial Loan Disclosures and a Settlement Services Booklet within 3 business days from the time of application. This excludes Sundays and Holidays. If the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement of Denial Letter”. THINGS TO REMEMBER - The 3 days begin the moment you enter the loan into Encompass or the moment you pull credit (which ever happens 1 st ). When preparing your initial disclosures, MAKE SURE that your GFE (Good Faith Estimate) is dated within 3 days of your file start date. Failing to do so will cause your LOAN to be OUT of Compliance. If you have pulled credit though your credit vendor YOU MUST enter the loan into ENCOMPASS within 3 days (and follow RESPA’s 3 DAY RULE) – remember your 3 days begins the day you pulled credit NOT the file start date. Your GFE must also be within those same 3 days (of credit). QUICK TIP Stamp an unsigned original RESPA package with an ORIGINAL STAMP and keep it in the file. We will AUDIT your credit report invoices to ensure you are following compliance. For simplicity and time management it is ideal to pull credit through Encompass Only. FILE START DATE DATE PREPARED Must be with in 3 days of the File Start Date – located in the log on the left. MAKE IT A HABIT Go directly to the GFE and put the date in the “Date Prepared ” field as soon as you have opened a new loan! STEP 3 PREPARING THE GFE Correctly preparing this document is crucial, it is a highly regulated form and filling it out incorrectly will also effect several other documents including your Truth and Lending Statement a.k.a. TIL, Reg Z (which is also highly regulated). DATE PREPARED - As mentioned it is VERY IMPORTANT that you enter the Date Prepared and follow the rules outlined in STEP 2. If you have DUPLICATED a previous loan; you will have to reenter the Date Prepared on the GFE or it will print the previous files Date Prepared. APR FEES – This section has already been completed for you as long as you create your loan using the templates as outlined in the ENCOMPASS TUTORIAL. Failing to follow this procedure will result in an inaccurate GFE and TIL and will cause you to be out of compliance.

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Page 1: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

“GETTING MY LOAN INTO COMPLIANCE” Following this tutorial will ensure that you are always in COMPLIANCE!

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STEP 1 – ENTER YOUR LOAN INTO ENCOMPASS USING THE METHODS FOUND IN THE ENCOMPASS TUTORIAL. http://www.topflitefinancial.com/BackOffice/Download/encompass-newhire.pdf STEP 2 – FOLLOW RESPA’s 3 DAY RULE. You are required to send your client (per RESPA) Initial Loan Disclosures and a Settlement Services Booklet within 3 business days from the time of application. This excludes Sundays and Holidays. If the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement of Denial Letter”.

THINGS TO REMEMBER - The 3 days begin the moment you enter the loan into Encompass or the moment you pull credit (which ever happens 1st). When preparing your initial disclosures, MAKE SURE that your GFE (Good Faith Estimate) is dated within 3 days of your file start date. Failing to do so will cause your LOAN to be OUT of Compliance. If you have pulled credit though your credit vendor YOU MUST enter the loan into ENCOMPASS within 3 days (and follow RESPA’s 3 DAY RULE) –remember your 3 days begins the day you pulled credit NOT the file start date. Your GFE must also be within those same 3 days (of credit).

QUICK TIP

Stamp an unsigned original RESPA package with an ORIGINAL STAMP and keep it in the file.

We will AUDIT your credit report invoices to ensure you are following compliance. For simplicity and time management it is ideal to pull credit through Encompass Only.

FILE START DATE

DATE PREPARED Must be with in 3 days of the File Start Date – located in the log on

the left.

Go directly to the GFE and put the date in the “Date Prepared” field as soon as you have opened a new loan!

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MAKE IT A HABIT

TEP 3 – PREPARING THE GFE orrectly preparing this document is crucial, it is a highly regulated form and filling it out incorrectly ill also effect several other documents including your Truth and Lending Statement a.k.a. TIL, Reg (which is also highly regulated).

• DATE PREPARED - As mentioned it is VERY IMPORTANT that you enter the Date Prepared and follow the rules outlined in STEP 2. If you have DUPLICATED a previous loan; you will have to reenter the Date Prepared on the GFE or it will print the previous files Date Prepared.

• APR FEES – This section has already been completed for you as long as you create your loan using the templates as outlined in the ENCOMPASS TUTORIAL. Failing to follow this procedure will result in an inaccurate GFE and TIL and will cause you to be out of compliance.

Page 2: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

QUICK TIP

APR FINANCE CHART Charges ALWAYS Charges NEVER Charges Included Unless

Included Conditions Are Met Included

CHARGE CONDITION Pre-Paid Late Interest Fee

Underwriting Insurance Premiums Consumer selected companyand signed disclosure

Fees for Title Insurance, Abstract, Examination 3rd Party Underwriting Property/Liability

Origination, Discount, Buy Down, Lock In Fees

Filing Fee prescribed by law and paid to Public Official

Tax Certification Fee Property Survey

Admin, Processing, 3rd Party Processing Fees

Charges imposed by Lender/Broker does not retain charge

Doc Prep Fee 3rd Parties Loan, Mortgage, Settlement

• YIELD SPREAD PREMIUM (YSP) – This fee must be spelled out in its entirety and must include an actual dollar amount.

THINGS TO REMEMBER – If your fees on your initial GFE are less then what you are charging at the time of closing (INCLUDING YSP), you MUST re-disclose 72 hours prior to close with the actual amounts that will be charged on the HUD-1 Settlement Statement. You must also change your Date Prepared to reflect this (72 Hour Re-disclosure Policy). Any FEE including YSP that has increased and has not been re-disclosed WILL be refunded back to the borrower.

• THIRD PARTY FEES – All third party fees charged (i.e. Courier, Credit, Appraisal, etc.) MUST be the amount actually incurred. You CAN NOT charge more then the invoiced amount. Failing to do so will result in the client being refunded the difference. You must also provide an invoice in order to receive any funds for these services; we will then pay the

Tax Service, Assignment, Recording Fees

Private and Mortgage Insurance (PMI/MI)

Life of Loan Monitoring Fee, Flood Insurance Fee

Mortgage Broker Fee

Lender Imposed Courier Fee

Warehouse Fees Wire Fees

All items listed in this category that is P.O.C.

Redraw Fees

Refinance Fee, Assumption Fee, Inspection Fee

Closing Agent, Notary, Attorney used to close

Notary Fee

Flood Determination Fee

Pest Control Fee

Appraisal, AVM, Review Fees

Charges absorbed by Creditor

Credit Report, Update Fees

Re-Conveyance or Recording Fee

Intangible Tax Fee, Mortgage Tax, Tax Stamp

Hazard Insurance

Closing Costs paid by BrokerYield Spread (YSP)

Finance Charge = Dollar Cost of Consumer Credit. It includes any charges payable directly or indirectly by the consumer and IMPOSED directly or indirectly by the creditor as a condition of, or incident to, the extension of credit.

Insurance Premiums Insurance not required disclosure Authorized Credit Life/Loss of Income

Always entering a new loan using the TEMPLATES found in Encompass will ensure that your APR CHARGES are accurate.

Page 3: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

provider directly (at the time of funding from the proceeds). Failing to charge an open invoice on the HUD-1 will result in a deduction in your commission to cover the expense. Failing to follow this policy will result in a $450.00 fine which will be deducted from the Loan Officers commissions for each occurrence.

REMINDER It is MANDATORY that all Vendors (Appraiser, *Title and Processing Co.) be approved prior to you ordering services from them. Failing to follow our Vendor Approval Process (Located under the Loans Tab in the TFF Back Office) will result in forfeiture of all loan commissions. For your convenience TFF has posted the APPROVED VENDORS in both the TFF Back Office (Located under the Loans Tab) and in Encompass (Located under the Business Contacts). *This does not apply to Purchase Transactions; Refinances only as TFF does not have the ability to choose a title company on Purchases.

STEP 4 – SENDING DISCLOSURES Disclosures can be generated through Encompass by email or by printing. Top Flite Financial has taken the guess work out of having to remember which documents are required and simplified this task by creating print groups for you to use regardless of which method you choose. Step 1: Click Print

and then select a FORM GROUP.

DID YOU RUN A MERS?

• Have you included any unknown

properties found in the MERS report on your REO?

• Did you run the findings based off of new info found in the MERS report?

If you have answered NO to any of these questions DO NOT SEND DISCLOSURES until you have completed.

Step 2: Click on the

SELECT ALL button.

Step 3: Click on the Custom Forms Tab. Select the Subject Properties State Folder and then select all required disclosures.

Step 4: Select Print or Email depending on the method you are using.

Page 4: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

THINGS TO REMEMBER BEFORE printing your documents.

• Be sure to double check your GFE and ensure that your DATE PREPARED is within the 3 Days and you have not left it blank before printing.

• Check to see if your Payment (PITI), Interest Rate, MI, are the same on your 1003 (page 2 –

proposed payment),1008, GFE and TIL (TIL Payment will not include Taxes and Insurance, only Principle, Interest and MI). If these do not match then you have locked your payment on page 2 of the 1003. See Diagram below.

• Be sure that your GFE and Details of Transaction on the 1003 (page 3) are the sa

includes Pre Paids, Closing Costs and Cash to or from the Borrower.

• Ask your self, “Did I create this using the provided templates?” If the answer is NOmust go through and manually do the 5 steps needed (found below) to ensuCOMPLIANCE. If you are unsure read the QUICK TIP below.

PIf you DO NOT see these line breaks then you have not opened your loan properly and will need to follow the 5 steps outlined above.

STEP 5 – After your loan closes. The first thing you will need to do is upload your loan into the ENCOMPASS EFOLDER folloFlite Financials Stacking Order. This form can be found by clicking on the link below. http://www.topflitefinancial.com/BackOffice/Download/ComplianceStackingOrder.pdf You will need to ensure that you have the most current stacking order prior to uploadloan. This document can be found by clicking on the link provided above or by goiCOMPLIANCE section in the TFF website.

FYI: Loans that are not scanned into Encompass (and are instead sent to the Corporate Offichard file) will be assessed a $49.00 Scan Fee for Full Packages (Processing and Closing Pacand a $29.00 Scan Fee for Half Packages (Closing Package from Title Company).

Click on the lock to unlock it and it will calculate the correct amount. You will have to save the file before printing.

me. This

then you re it is in

STEP 1 – Select the TEMPLATE tab at the topof your screen. STEP 2 – Select LOAN PROGRAM from thedrop down and follow the prompts. STEP 3 – Select FORM LIST from the dropdown and follow the prompts. STEP 4 – Select APPEND DOCUMENT SETfrom the drop down and follow the prompts. STEP 5 – Select APPEND MISC. DATATEMPLATE from the drop down and follow theprompts.

QUICK TI

wing Top

ing your ng to the

e as a kage)

Page 5: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

CAUTION: Do not shred your documents after scanning. All scans must be saved for a minimum of 30 days. Please also ensure that your scan is legible (if not you must RESCAN).

Step 1 – While in your clients loan Select the Efolder Tab in Encompass.

The following screen will appear once

Creating a folder labeled “Encompass Files” on your desktop and sending all of your scanned documents here will minimize the time spent searching.

QUICK TIP

StedocyouAss

Step 2 – Select the Manage Documents button.

you have selected Manage Documents.

Step 4 – The Pop Up shown here will appear once you have clicked on the Browse and Attach. You will then search for your scanned documents and click on the OPEN button once found.

Step 3 - Select the Browse and Attach tool.

p 5 – Once your ument has loaded will then click the ign As button.

Step 6 – The following Pop Up will appear upon hitting the Assign As button. You will then label your documents as described in the stacking order and shown on the left. Upon completion click the ADD button.

Page 6: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

The second thing that must be done is to enter your loan into the www.topflitefinancial.com Loan Log. This is required and must be done to receive commissions.

Step 1 – Log Into your back office and select the LOANS tab.

Step 2 – Select the LOAN LOG button.

Step 3 – Select the NEW LOAN button.

Step 4 – Complete all fields in the LOAN INFORMATION section.

STEP 6 – File Audit This step is preformed by the Quality Control department at Top Flite Financials Corporate Office, once we have received the closing package and loan funds. Your loan will be thoroughly checked to ensure that it meets all State and Federal regulations. Upon completion you will be notified as to whether it is In Compliance or Out of Compliance.

Page 7: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

LMthfo Yo

TC

FOR QUICKER FUNDING You can now have your commissions wired to TFF (from the title company). Complete the Wire Transfer by clicking on the link below.

https://www.topflitefinancial.com/BackOffice/Download/WIRE_TRANSFER_SHEET.doc

OANS in compliance by Friday at 3:00 pm EST will be paid out the following Friday and sent via US ail. If you would like to receive your commissions via direct deposit you may do so by clicking on e link http://www.topflitefinancial.com/BackOffice/proshop/EmployeePackage/directdeposit.pdf and rwarding the completed document to us via fax at 517.772.5918.

We will not be responsible for delay of payroll due to outdated personal information.

ou will ONLY be notified via your internal email (located in your back office) as to the status f your loan (In compliance/Out of Compliance.

INTERNAL EMAIL is located under the News and Updates section.

he following screen will appear notifying you of the borrower and whether it is in compliance or not. licking on the subject line will redirect you to the loan in the loan log.

Our Quality Control Department will during their review, use the worksheets (found below) to AUDIT your loans. It is recommended that you pre audit your files before submitting. This will ensure that you are in Compliance prior to funding and that your commissions are not held up.

Please make sure that we have your correct address on file and/or banking info for those with direct deposit. You can verify this under the HR TAB in the TFF back office. If the information is inaccurate please fill out the Employee Change form and fax to Abbe at 517.772.5912.

https://www.topflitefinancial.com/BackOffice/proshop/EmployeePackage/Employee_Change_Form.doc

Page 8: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

T

LOAN APPL

SIGNED BY LO LO LICENSE NUMBER ON 1003 IF APPLICABLE BORROWERS SIGNED ALL PAGES ( DETAILS OF TRANSACTION ON PAG TOTAL PAYMENT ON PAGE 2 OF TH P, I AND MI PAYMENT MATCHED TIL H.M.D.A. SECTION IS FILLED OUT

TRANSMITTAL

PAYMENT MATCHES 1003/GFE/TIL

GOOD FAITH E DATE PREPARED IS WITHIN 3 DAYSSTART DATE WHICH EVER COMES YIELD SPREAD PREMIUM IS SPELLE PFC CHARGES ARE CORRECT – PE

SIGNED AND DATED BY CLIENT

FEES MATCH DETAILS OF TRANSAC

TRUTH IN L

DATE PREPARED IS WITHIN 3 DAYSSTART DATE WHICH EVER COMES P,I, AND MI MATCH PAYMENT ON 10 PROPERTY INSURANCE AND FLOO

FILING FEE $45.00 LATE CHARGE = 15 DAYS AND 5%

PREPAYMENT = MAY OR MAY NOT ASSUMPTION = MAY NOT OR MAY N SIGNED AND DATED BY CLIENT APR ISN’T MORE THEN 8% OVER TH

BORROWER AUT SIGNED AND DATED BY CLIENT

DISCLOSURE

DATE PREPARED IS WITHIN 3 DAYSSTART DATE WHICH EVER COMES ALL SECTIONS SIGNED AND DATED

EQUAL CREDIT O

ADDRESS: Federal Trade Commissio 600 Pennsylvania Ave. NW Washington, DC 20580 SIGNED AND DATED BY CLIENT

TOP FLITE FINANCIAL LOAN AUDIT WORKSHEE

ICATION -1003 MTG. LOAN ORIGINATION AGREEMENT - MLOA

Y

N

ACT NO 173, PUBLIC ACT 1987, AS AMENDED

Y

N

Y

N

DATE PREPARED IS WITHIN 3 DAYS OF THE CREDIT OR FILE START DATE WHICH EVER COMES FIRST.

Y

N

AND TOP OF PG 1 IF JOINT)

Y

N SIGNED AND DATED BY CLIENT

Y

N

E 3 OF 1003 MATCH GFE

Y

N STATE SPECIFIC MLOA - IF APPLICABLE

Y

N

E 1003 MATCH THE GFE

Y

N

Y

N

PATRIOT ACT DISCLOSURES

Y

N

INFORMATION DISC. – SIGNED AND DATE D BY CLIENT

Y

N

SUMMARY - 1008

CUSTOMER ID DOCUMENT – COMPLETED BY LO MUST HAVE COPY OF DRIVERS LICENSE AND SS CARD

Y

N

Y

N

4506 – T

STIMATE - GFE

COMPLETELY FILLED OUT WITH LAST 2 YEARS REQUIRED Y N

OF THE CREDIT OR FILE FIRST.

Y

N

SIGNED AND DATED BY CLIENT Y N

D OUT (NOT JUST YSP)

Y

N

NOTICE TO RECEIVE APPRAISALR APR CHART

Y

N

RIGHT TO RECEIVE = 90DAYS

Y

N

Y

N

CONTACT ADDRESS IS AVAILABLE

Y

N

TION ON 1003

Y

N SIGNED AND DATED BY CLIENT

Y

N

ENDING - TIL

FAIR LENDING NOTICE

OF THE CREDIT OR FILE FIRST

03 AND GFE

Y

N

D CHECKED Y

N

Y

N

ADDRESS: Office of Fair Housing and Equal Opportunity Y N Dept of HUD – Room 5204 451 Seventh St. SW Washington, DC 20410-2000 US Dept of HUD Ralph H. Metcalf Federal Building 77 West Jackson Blvd. Room 2101 Chicago, Il 60604-3507

Y

N

DATE PREPARED IS WITHIN 3 DAYS OF THE CREDIT OR FILE START DATE WHICH EVER COMES FIRST

Y

N

HAVE TO PAY A PENALTY

Y

N SIGNED AND DATED BY CLIENT

Y

N

OT

Y

N

Y

N

SETTLEMENT SERVICE PROVIDERS

E CURRENT 30 YEAR TBILL

Y

N SIGNED AND DATED BY CLIENT

Y

N

HORIZATION Y

N

PRIVACY NOTICE

Y

N

SIGNED AND DATED BY CLIENT

Y

N

NOTICE Y

N

TFF 3 PART DISCLOSURE

OF THE CREDIT OR FILE FIRST.

Y

N

SIGNED AND DATED BY CLIENT

Y

N

BY BORROWER Y

N

INDIVIDUAL/JOINT CREDIT ADDENDUM

CORRECT BOX CHECKED

Y

N PPORTUNITY ACT

SIGNED AND DATED BY CLIENT

Y

N

n

Y

N

SERVICING DISCLOSURE

MOST CURRENT 3 YEAR HISTORY = 100% ALL BOXES MARKED TO REFLECT (ALL TRANSFERRED)

Y

N

Y

N

SIGNED AND DATED BY CLIENT

Y

N

Page 9: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

FACT ACT DISCLOSURE

POST CLOSINGSIGNED AND DATED BY CLIENT Y N APPRAISAL INVOICE Y N

PAID IN FULL Y N BALANCE DUE (If applicable) $____________ Y N

FHA DISCLOSERS ALL DISCLOSURES MUST HAVE A DATE PREPARED WITHIN 3 DAYS OF

THE CREDIT OR FILE START DATE WHICH EVER COMES FIRST PAYMENT STATUS MATCHES HUD Y N HUD ADDENDUM – SIGNED AND DATED BY CLIENT OVER CHARGE (if applicable) $____________ Y N MCAW – SIGNED AND DATED BY CLIENT Y N CREDIT REPORT INVOICE Y N NOTICE TO HOME BUYERS – SIGNED AND DATED BY CLIENT Y N INVOICE AMOUNT MATCHES HUD Y N BLANKET SIGNATURE – SIGNED AND DATED BY CLIENT Y N OVER CHARGE (if applicable) $____________ Y N AFFILIATED BUSINESS DISC. – SIGNED AND DATED BY CLIENT Y N COURIER FEE INVOICE Y N APPRAISAL NOTICE – SIGNED AND DATED BY CLIENT Y N INVOICE AMOUNT MATCHES HUD Y N AMENDATORY CLAUSE – SIGNED AND DATED BY CLIENT Y N OVER CHARGE (if applicable) $____________ Y N ASSUMPTION NOTICE – SIGNED AND DATED BY CLIENT Y N SURVEY INVOICE Y N CONSUMER CHOICE – SIGNED AND DATED BY CLIENT Y N INVOICE AMOUNT MATCHES HUD Y N

OVER CHARGE (if applicable) $____________ Y N OTHER INVOICE ______________________________ Y N

VA DISCLOSURES ALL DISCLOSURES MUST HAVE A DATE PREPARED WITHIN 3 DAYS OF

THE CREDIT OR FILE START DATE WHICH EVER COMES FIRST INVOICE AMOUNT MATCHES HUD ELIGIBILITY CERT – SIGNED AND DATED BY CLIENT Y N OVER CHARGE (if applicable) $____________ BORROWERS RIGHTS – SIGNED AND DATED BY CLIENT Y N LOAN DISBURSE – SIGNED AND DATED BY CLIENT& SPOUSE Y N

HUD – 1 STATEMENT

REASONABLE VALUE – FORM 26-1805 – SIGNED BY LO Y N FINAL SIGNED Y N MILITARY CHECKLIST – SIGNED AND DATED BY CLIENT Y N MATCHES GFE – IF NOT, REFUND AMOUNT $____________ Y N DEBT QUESTIONNAIRE – SIGNED AND DATED BY CLIENT Y N FEDERAL COLLECTION – SIGNED AND DATED BY CLIENT Y N

NOTE

VERIFICATION OF BENEFIT – SIGNED AND DATED BY CLIENT Y N ARM RIDER – IF APPLICABLE Y N RATE/DISCOUNT DISC. – SIGNED AND DATED BY CLIENT Y N PRE PAYMENT RIDER – IF APPLICABLE Y N AMENDMENT TO CONTRACT – SIGNED AND DATED BY CLIENT Y N FULLY EXECUTED Y N VA TRANSMITTAL LIST – SIGNED BY LO Y N REQUEST OF VETERAN STATUS Y N

MORTGAGE

HUD/VA ADDENDUM Y N FULLY EXECUTED Y N

STATE SPECIFIC DISCLOSURE ALL DISCLOSURES MUST HAVE A DATE PREPARED WITHIN 3 DAYS OF

THE CREDIT OR FILE START DATE WHICH EVER COMES FIRST FUNDS

ALL REQUIRED DISCLOSURES (PER ENCOMPASS) Y N CHECK RECEIVED – AMOUNT $___________________ Y N

BROKER FEE MATCHES HUD Y N

FINAL DISCLOSURES PROCESSING FEE MATCHES HUD Y N

FINAL 1003 – SIGNED AND DATED BY CLIENT Y N

GFE – DATED 72 HOURS PRIOR TO CLOSING

PROCESSING FEE IS MADE PAYABLE TO TOP FLITE FINANCIAL OR APPROVED 3RD PARTY PROCESSING COMPANY – NOT A MANAGEMENT CO. IF MGMT AMOUNT REFUNDED TO CLIENT$____________

Y N

FIGURES MATCH HUD Y N YSP MATCHES HUD Y N INTEREST RATE MATCHES INTEREST RATE AT CLOSE Y N ORIGINATION FEE MATCHES HUD Y N MARI – INITIAL AND FINAL (Properties match REO )

Y N OTHER FEE _____________________MATCHES HUD Y N

ANY THIRD PARTY PAID TO TOP FLITE MATCHES HUD Y N

QC CHECKLOAN DOCUMENTS IN ENCOMPASS Y N LOAN OFFICER LICENSE STILL ACTIVE Y N CHECK SIGNATURES ON ALL DOCUMENTS Y N INSPECT HUD FOR INCONSISTENCIES IN PURCHASES Y N LOAN ROLLED TO COMPLETED IN ENCOMPASS Y N COMMISSION CALCULATED Y N THIRD PARTY FEES TAKEN OUT OF FUNDS Y N OVER CHARGE FEE OF $25.00 ASSESSED & DEDUCTED Y N

AUDIT NOTES: ________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ BORROWER:________________________________________________ LOAN OFFICER:____________________________________________ COMPLETED BY:_________________________________________________________________________ DATE:_______________________

Page 10: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

STEP 7 – I AM OUT OF COMPLIANCE If your loan is marked out of compliance you will need to go into your loan log and check the LOAN LOG NOTES for explanation. This is your responsibility and you will not be notified by any other means.

Where to find Loan Compliance Status

OUT OF COMPLIANCE FINE PROCEDURE

All loans that are marked out of compliance by TFF corporate compliance department will be assessed a fee of $10 per day up to 45 days. This fee will be waived on all loans that are cleared within 14 days of the original audit date. If the loan is still not in compliance on the 15th day you will be assessed a fee of $150.00 and then $10.00 dollars per day until the loan is deemed to be in compliance. If after 46 days the loan still has not been cleared for compliance – ALL LOAN COMMISSIONS will be forfeited and a $450.00 fine will be charged to the Branch Manager

Loans that can not ever be put into compliance will immediately be assessed a $450.00 Fine that will be deducted from the Loan Commissions and then cleared for payroll that week. The following is a list of examples of items that can not be fixed: Loan Docs Dated and Disclosed after 3 Day RESPA rule, Import Date is not within 3 Days of Credit or Application, Not *Re-Disclosing with in 72 Hours, Details of Transaction does not Match GFE or TIL, PAYMENTS are different on 1008, TIL, 1003, GFE – (TIL will not include T&I).

*You will lose the difference of monies from initial GFE vs. the HUD. This will be returned to the borrower.

FHA LOANS that have been originated by a Licensed Realtor and/or has employment with a mortgage related entity (Appraiser, Title Company, Etc.) will FORFEIT ALL COMMISSION and Branch Managers will be assessed a $450.00 Fine.

ALL Commissions on Loans that have found to be FRAUDULENT will be forfeited regardless if it was Borrower or LO Fraud.

Repeated Offenders will be reviewed by the Audit Advisory Board and termination may be considered.

PLEASE NOTE: TFF will not assess any FINES on the first 5 Loans of any new branch (unless it is found that it is contains FRAUD or violates the FHA/DUAL EMPLOYEE rule). We want to ensure your success and will use this time as refresher training on TFF policy and procedures.

TFF could be fined up to $1000 per violation of any Federal lending law, please take time to fully understand this compliance training tutorial so we can eliminate the costly and negative exposure caused by carelessness. Thank you!

This section will give you details as to what is wrong with your file if it is out of compliance. It will also show any invoices that were paid out and additional audit notes if applicable.

After you have corrected the items needed by the Compliance Department you will (which includes uploading the corrected and/or missing documents needed in to the Encompass Efolder – DO NOT fax or email them to TFF.) need to post a note in the Loan Log, stating that the loan is now in compliance.

Page 11: “GETTING MY LOAN INTO COMPLIANCE” · the loan is withdrawn or denied with in those 3 days then you do not need to send initial disclosures; INSTEAD you must send a “Statement

Step 1 – Open your loan in the TFF LOAN LOG.

Once yoCOMPLIAearned Summarylog).

Thank you for taking the steps to eletter acknowledging that you haveAbbe at 517.772.5912. I ___________________________Financials Compliance Policies. I uand the possibility of my termination _____________________________Signature _____________________________Date

Step 2 – Enter your note in the Loan Officer Note Section. F.Y.I. You will also use this to converse back and forth with the Compliance Dept.

Step 3 – Click on the SAVE button. This will post and time/date stamp your response and email it to the Compliance Dept.

ur Loan has been marked IN NCE, you will be able to see your commissions in the Closing (located at the bottom of the loan

nsure that your loans are in compliance. Please sign the below read and understand our policies and fax this page (pg. 10) to

________ hereby understand and will comply with Top Flite nderstand that failing to do so could result in delayed pay, fines, .

_______________

_______________