Comments on: Quarterly MARI Report

By: Angie Williams

Angie Williams — Thu, 27 May 2010 01:14:30 +0000

During the bubble, I worked for a large company.. mortgage sweat shop if you will. There were no mortgage fraud detection systems in place that I was aware of… only one encouraging.. go get em.. don’t ask a lot of questions .. sort of supervisor. Volume was key and for that you were awarded. There may have been a system in place at the processing center. That I am not certain of as I never had anyone question of fraud on a file. Nor was it practiced at the origination end.

Our company is small and there are many checks and balances at every stop. Educated seasoned originators. Processors who know how to be a detective with their available resources and an underwriter who has seen it all.

Our processors have a comfortable open supervising staff which they or I can go to if they have suspicions.

By: Daniel Mulvehill

Daniel Mulvehill — Sat, 27 Feb 2010 16:42:52 +0000

The Mortgage Asset Research Institution is a great standard to implement within your Mortgage Operation, the firm I have worked with uses an external source for QC, and that representative is within the office of coarse there own private office, so prior to funding it’s reviewed by a subordinate and then to closing and then to QC for delivery to the Secondary market, also your files out of the blue when put on Calyx were picked up after hours and reviewed just to see how you were managing your pipline, conditions etc, this I liked because there were LO’s not paying attention and of coarse possible other issues as well?

By: Alison Clark

Alison Clark — Wed, 24 Feb 2010 00:47:06 +0000

At the time of this article I worked for a small brokerage and we had compliance in the hands of the processor only unless their was a problem then it was handed to the company manager who then addressed any problems with the LO on the file. I was taught from the beginning when I started to work in processing in 2001 what to look for, and the guidelines just got stricter as we moved forward.

Today I work for a correspondent lender and compliance starts with the processor then to the underwriter then to our QC department then to funder PTF and post closing after.

I had a situation where I had to report a LO just last year (not licensed in state originating), I reported him to corporate they reported him to Oregon authorities as the loan was in Oregon. He was terminated, there was no retaliation against me from the LO. Our corporate office took responsibility and called the customer to assure them the loan they needed was still available at without the fees charged by LO at better rate and I still received my processing fee. If I have to report someone I am doing a service to my fellow man and am not worried about retaliation from an unscrupulous LO.

By: Chris Yanke

Chris Yanke — Wed, 30 Dec 2009 21:37:42 +0000

With regard to the internal mechanisms of the companies I’ve worked with recently the first thing that would be done is either to have a processor perform the duty of verifying employment, deposits, etc.. This was good for sake of integrity but not always good for timing. Often what I would do is perform the verifications of employment through mail/fax with the HR person providing contact information on my form to verify by a 2nd party if necessary.

Today the procedures are more stringent because they not do a post funding audit for state compliance, but the institutions also will randomly verify employment afterwards as well. Our company has an internal Wa. State Compliance procedure to meet documentation requirements as per DFI regulations. Failure in any of these results in having to buy back the loan or repay comission.

Answer to question number 3: I am not sure how this would be dealt with since I’ve never had to put my processor in a situation that would require this. But I would see very quickly this going straight to the top and having a manager/senior broker become immediately involved as these actions can affect them and their futures as well.

By: Yvette

Yvette — Fri, 18 Dec 2009 06:28:51 +0000

I am a one person office as some of the others on the post. I process my own files but I do not solicit for business. I only work with people that have been referred by others I have worked with or know personally. I tried to read the link http://www.rybconsulting.com/ but I was unable to pull it up. I know that even people you know are not honest.

I do not think anyone can really know someone for sure, but you think if you surround yourself with good people they surround themselves with good people.

Since, I am a broker and I am not a correspondent lender all of my files I submit to lenders also have strict compliant rules for files they will accept. They make sure that I am within the three days, they have a system in place for verification of all of the information that I submit and they will not fund files until they have verified with the borrowers employer that they are still employed on the day of funding. The company that I use also goes through Rapid Reporting that verifies their social security number.

Hopefully all these measures will work. I think the best crooks are not sloppy but rather good at what they do, they do get caught eventually but sometimes not before they get away with millions.

By: Raylene Ramos

Raylene Ramos — Thu, 23 Apr 2009 22:26:45 +0000

Our company does all the underwriting and verifying of income as the LO’s submit the information. There is no subprime lending, adjustable rates, interest only loans available through our company, only fixed rate loans. All LO’s are also checked out with a federal background check. All suspicious activity is to be immediately reported to our home office and disciplinary action or termination is required.

By: Mary McGraw

Mary McGraw — Tue, 21 Apr 2009 23:14:41 +0000

I belive that there should only be certain people seeing over things so they can pay attention to whats going on and see if fraud is being done. If there is to many its hard to keep track of what everyone is doing. Where i work we have certain people watch and take care of things so it doesn’t happen.

By: Chris Madden

Chris Madden — Sat, 28 Feb 2009 17:36:38 +0000

I have never been a part of or seen fraud in my office. We have pre, and post-close audits in place to make sure every loan is in compliance.

By: Sharon Eva

Sharon Eva — Wed, 11 Feb 2009 19:33:35 +0000

All of our loans must be processed by the “in house” processor or approved outside processing companies. All loans must be registered with corporate and files must be reviewed by the compliance department when registered and when closed. If there are any errors the compliance department notifies you and must make corrections, write letters to explain errors/changes, etc. Our compliance department is very extensive. I’m not sure if we ave a special hotline for suspect of fraud but I would inform DFI or my superior.

By: Teresa Tait

Teresa Tait — Wed, 11 Feb 2009 02:41:52 +0000

I actually started working in this industry 6 yrs ago during the boom.I worked for a broker affiliated with a Bank so I was trained on compliance immediately. We also had in house processors as we were not allowed to process our own files. After each loan funded the entire file had to be examined by one of our brokers and signed off before we could submit it to payroll. It actually worked very well. I am sure that it prevented unintentional errors and ensured compliance however I do think that if someone was determined enough to change something that they could have.
I now work for a broker also affiliated with a Bank and they actually have a compliance department in place. They also require all processors, appraisers etc to be approved by them. It makes for a much tighter operation, which I am thankful for.

By: Robert Paterson

Robert Paterson — Sat, 07 Feb 2009 01:03:38 +0000

I specialize in reverse mortgages. All our paper work is completely different. Before a person can apply for a reverse mortgage they have to go through counseling. The client can ask the counselor anything they want costs(which are set by FHA) timing process literally anything. The company I work with has a loan processor and a compliance department. All appraiser for reverse mortgages are FHA appraisers and the bank I use has an appraiser exclusionary list. Still if you are shady and can find a shady FHA appraiser it would be pretty easy to get an inflated appraisal.

By: Scott

Scott — Tue, 27 Jan 2009 01:23:03 +0000

We are affilated as a branch office that has compliance officers to review all files. Also being a one person office we will be atending to all details in an honest fashion

By: Carla

Carla — Wed, 14 Jan 2009 01:19:46 +0000

We use a compliance checklist during processing and another at the time of closing. Compliance training is mandatory. Hiring those with high integrity is imperative.

By: Mary Schimmelbusch

Mary Schimmelbusch — Wed, 31 Dec 2008 23:03:19 +0000

I am a contract processor and I make sure the LOs that I work for has a compliance dept. I am very strict and I have a zero tolerance policy as well.

By: Cheryl J Barr, 510-LO-38949

Cheryl J Barr, 510-LO-38949 — Wed, 31 Dec 2008 20:24:56 +0000

There are only 3 people in our company. We have all worked together for over 10 years. Our broker has always been a big stickler on disclosure, doing make sense loans. We have said no to more than a few people over the past years. However, we are all in it for the long haul. With that said we check each other for mistakes and also review apprasials, P & S, and escrow workings as a regular proceedure. I have had a chance to work other places but choose to work for a my broker, a man with integrity.

By: Joe Hrebik

Joe Hrebik — Wed, 31 Dec 2008 19:42:28 +0000

I’m currently being sponsored by a new company so I cannot make any specific comments but I do have a general observation… the culture of the company has to be one that encourages its employees to report any suspicious activity to mgmt without fear of reprisal. This should include some sort of ongoing training, educating employees of the company policy towards fraud on a regular basis.

I found it interesting that Florida and California were at the top, guess criminals go after ocean view properties. I also found it interesting that MARI recommends making sure applications are correct at submittal, with criminals using rejections as a learning tool to circumvent the system.

By: John Sarausad

John Sarausad — Wed, 31 Dec 2008 08:52:31 +0000

We also have a compliance manager that makes sure all of our files are in compliance and aren’t in “fraud alert”. This is extremely important to protect the LO and company in case an auditor is going through your files. It is best to be proactive with all our clients instead of reactive.

By: John Sarausad

John Sarausad — Wed, 31 Dec 2008 08:50:43 +0000

Fortunately, I split the work between me and a co-worker. I make sure to go over every single piece of paper that is in every single file. These are the times where our files need to be tighter than they ever have. There is no room for fraud. If fraud is suspected, it is confronted right away. Fortunately this is something that I have not ran across recently, but my eyes are wide open on catching anything fishy before it starts.

By: Susan Lohse

Susan Lohse — Wed, 31 Dec 2008 06:56:55 +0000

The brokerage company I work for has a full compliance department, as well as a full processing team. They provide regular compliance training seminars and encourage loan officers to take them at least every couple of months as updates come about so often. Last summer I processed a loan that I also originated and had a couple of compliance that held up my commission check at the end. I now have the processing team process all my files because it’s just not worth my time anymore.

By: shelley safronek

shelley safronek — Tue, 30 Dec 2008 20:45:00 +0000

I am a one person office so I am the fraud detector single handedly. Prior to 2004, I did have a processor and an assistant all of which I trained the old fashioned way. Underwrite the file as if the money is your own! REview the 1003, review the paystubs, assets, gift letters etc. and see if it all makes sense. Ensure addresses match up with credit report that match up with bank statements that match up with W2’s! It’s really not that difficult as most people that commit fraud are really not that bright. I have seen fraudulent documents come across my desk and I cancel the file right then and there. My experience has been the crooks are sloppy and they do leave holes. I have been fortunate to not come across the real sophisticated crooks as my business is referral based. I have great referrals!

By: Brian Paine

Brian Paine — Tue, 30 Dec 2008 18:45:09 +0000

Our broker is a man of integrity. It’s all trickle down management in my opinion and clear communication.

At it’s peak there were about 20 LOs in our company. If fraud was detected by our processor protocol went to our “trained” office mgr who then went to our broker. He then would, one, dismiss the LO and, second, alert MARI and/or DFI about the activity. He’s ultimately responsible for those he hires and takes great pride in our status with the BBB as well as the seriousness of the relationships we have with all of our clientele.

By: Dennis Tyler

Dennis Tyler — Tue, 30 Dec 2008 02:57:05 +0000

Our processor is a past underwriter. My assistant is a past compliance officer. Our funding department is totally separate and adheres to a very strict set of guidelines. Audits are performed regularly. We only hire good people.

By: Jim Haechler

Jim Haechler — Tue, 30 Dec 2008 00:25:29 +0000

Our company has a strict compliance department that over sees everything. It also has a zero tolerance policy. It also has on going training to help new and old LO’s.

By: William Schornack

William Schornack — Tue, 30 Dec 2008 00:02:28 +0000

Our office has a full time compliance department, and a zero tolerance policy. All files are reviewed.

By: Jim LaLone

Jim LaLone — Mon, 29 Dec 2008 22:26:51 +0000

I guess fraud is aways present, no matter if its a freind , refferal, or relative, or politician. Ask those dudes that ran fannie and freddie in to the ground….Bonus’, incentives, favors, its all part of the game. Were just a small office in a small town that I have worked and grown up in for many years,so it seems a little less risky. In addition, we have smart,savy, gracious and beatiful processor. [she's reading this] She’s also blonde, how did that happen?