It can be argued that the current mortgage market is not so much a victim of fraud and unsuitable loans, as it is a victim of one of the largest procedural failures in the history of our industry.
Quality enforcement is no longer a "nice to have". It is required to stay in business.
A Quality Control Plan exhibits the policies and procedures that companies consider the responsibility of every employee. This plan follows both requirements of key government agencies and primary mortgage investors and is a vital resource to ensure a company’s mission is achieved. While many mortgage companies effectively maintain and execute a Quality Control Plan, just as many have pulled out that 3 ring binder that was gathering dust in the back room closet and are reviewing, revamping and reinstating their policies.
Besides ensuring that companies originate loans in compliance with Federal and State laws, an effective Quality Control Plan is also necessary to ensure that loans are salable in the secondary market. Gone are the days of slipping in the “iffy” file and hoping it is not one of the 10% selected for review. Be assured that in today’s world, each and every loan will be assessed somewhere along the line.
Objectives in a company’s Quality Control Plan should include:
- Protection of unacceptable risk for the company, the correspondent investors and all governmental agencies.
- Ability to ensure integrity for all loan origination and processing functions.
- Ability to ensure compliance with the requirements of the investors who buys the loan, the government agencies that insures and/or guarantees the loan, and the state and federal laws that govern origination functions.
- Insulating the company, the correspondent investors and all governmental agencies against errors, omissions, material representations and fraud.
- Defined effective and efficient corrective actions when problems are identified.
A company’s Quality Control Plan must be implemented throughout each step of the loan process. It is imperative these steps are thorough and employees have been properly trained, all while on- going checks and balances are maintained.
Specific Quality Control steps to be developed include, but are not limited to:
- Loan Origination
- Application and Disclosures
- Credit reports and review
- Verifications
- File audit and review
- In-house Processing
- In-house/Lender Underwriting
- Closing
- Documentation
- Fraud and compliance
- HUD 1 review and approval
- Funding
- Post-Closing review
- Purchase Clearing
The Quality Control Plan should also include the process for independent quality control audits which will involve the evaluation of the company’s best practices and denied loan application reviews.
Developing a Quality Control Plan can be labor intensive and costly if not developed thoroughly and/or not implemented strictly. Be smart by making sure your Quality Control Plan is complete, your employees are trained, and your internal control audit and compliance checks on loans are proving the quality control standards you have set in place. Consistency in process compared with the implemented written plan will demonstrate integrity within your mortgage operations.
For those of you who are now thinking “I need to review my plan,” the automation of the quality control process is now an inexpensive and manageable reality for everyone. There are countless tools and services available in the market place.
If you don’t know how to do it yourself, Titan can provide direction and/or perform the needed services to shore up your lending operations. If you need introductions to the top fraud and compliance vendors, we can make them. Or if you prefer, you gain access to these same vendors through our services. |