Lender Drops FICO From Underwriting Decisions; Stearns' TRID Defects

By: Rob Chrisman

I'd recently heard of an English teacher in high school who preached, "Practice safe text, use commas...and never miss a period." How about never miss a cyberattack? Thank you to Sue W. who sent along this hypnotic map of cyberattacks in real time. (Don't ask me if it is real; I think it was part of a Mathew Broderick movie.) On topic, Gartner research finds on average it takes 32 days to detect an insider threat and it takes 17 days for companies to respond. The research also finds the top insider threats are related to data leaks (63%); inadvertent data breach (57%); malicious data breach (53%); fraud (36%); intellectual property theft (29%); espionage (23%) and sabotage (20%). Lastly, cybersecurity policies will be a top examination priority according to this week's guidance from the Securities and Exchange Commission's Office of Compliance Inspections and Examinations.

Stearns Lending recently released its top TRID deficiencies in order to ensure efficiency of purchase transactions. The list includes the closing disclosure was not disclosed to the borrower within 3 businesses days of the closing date, loan estimate not disclosed to the borrower within 3 days of the application date, borrowers not receiving the loan estimate within 4 days of the closing date, loan estimate reflects a pre-payment penalty, origination charge increased from loan estimate to final closing disclosure, lender needing to provide escrow waiver, lender needing to provide a fully executed copy of the final closing disclosure, and the lender needing to provide a valid change of circumstance for all subsequent loan estimates.

Earlier in the week this commentary published a list of recent changes in lender requirements regarding credit scores, along with a bill introduced in Congress about having Fannie & Freddie move away from Fair Isaac's calculations. Coincidentally the Wall Street Journal published a story about how the industry is questioning FICO's reign on all underwriting decisions.

Sure enough news broke that one well-publicized lender is indeed doing away with FICO - investor reliance on the number be damned - much to the glee of real estate agents, builders, and NAR who see the credit box expanding. "Following a successful pilot program that began in the fall of 2015, leading online lender SoFi announced that it no longer factors FICO scores into its loan qualification process. Instead, the company considers three criteria - employment history, track record of meeting financial obligations and monthly cash flow minus expenses - to determine if an applicant is qualified for its loan products, which include student loan refinancing, mortgages and personal loans.

"Banishing traditional credit scores stems from SoFi's belief that the FICO model is flawed and outdated; it's less of an indicator of how a borrower will behave in the future, but rather, a reflection of past behavior. While the industry is moving toward evaluating non-traditional factors during the application process, most lenders still incorporate FICO scores into their proprietary algorithms and underwriting models. Having now funded more than $6 billion in loans, SoFi is the first large lender to become an entirely 'FICO-Free Zone.'"

"'Our approach to underwriting is based on transparency and balancing the needs of our members and investors, and we found that the FICO score was anything but transparent. So we threw it out,' says CEO and co-founder Mike Cagney. "We're proud to be the only major lender that does not use the score for any lending. Instead of relying on a three digit number to tell us who's qualified, we look for applicants who have historically paid their bills on time and make more money than they spend. It's that simple.'"

A recent survey commissioned by Bankrate and compiled by Princeton Survey Research Associates International found that 63 percent of Millennials - ages 18 to 29 - don't have a credit card, showing that credit scores are becoming less relevant for this generation. The industry at large is also examining the accuracy of FICO; if passed, the Credit Score Competition Act of 2015 will allow Fannie Mae and Freddie Mac to use credit scoring models other than FICO.

Yes, the majority of Millennials don't have credit cards, may never have them, and plenty of Millennials pay rent. Kristin Messerli sent me a note saying, "I think mortgage lenders should be aware of a few things as this generation's home buying surge will eventually hit the market. First, while there is significant growth already in the Millennial homebuyer segment, now comprising the largest share of home buyers according to NAR, that does not translate to the same growth across the industry. Millennials, unlike any previous generation, approach purchasing decisions with seemingly limitless access to information about all options on the table. Having grown up with access to information at our fingertips at all times, we have developed a natural method of fairly extensive research prior to making any purchasing decision, which relies heavily on peer reviews and assessment of value. Millennials hope to find a loan officer with whom we can trust and who will bring the greatest expertise, and we won't settle until we find the best 'value' for us.

"The problem I have found in the mortgage industry is that many loan officers may have these traits, but that message is often not being conveyed to their prospective consumers. In order to reach a greater share of Millennials, loan officers must learn how to convey their message of quality and trust to us before we pass you over for another lender. In order to do this effectively, loan officers should be aware of the cultural differences among the generations, how to create a service experience their consumers want to share with their peers, and how to market that service experience in a language Millennials understand. 

"As Millennials and multicultural segments make up the majority of household growth, it is more critical than ever that companies engage in culturally specific training. For example, and as a bit of a sales pitch, my company, Cultural Outreach Solutions, has developed a new training platform called Culture MAP (Market Access Plan), designed to empower loan officers with the information and tools to increase production with Millennial and multicultural consumers."

Turning to the bond markets, how about these rates! Of course, as I've mentioned a number of times, a change in Fed Funds doesn't mean a change in mortgage rates, and look how much lower long-term rates are now versus mid-December when the Fed raised rates. Although mortgage-backed securities lagged a little, we had a nice improvement in rates Wednesday as falling oil and stock prices as well as a well-subscribed $21 billion 10-year note auction generated strong demand for fixed-income assets. And the Fed's Beige Book for January showed expanding economic activity in 9 of 12 regions - fine here, but overseas news continues to drive our markets.

Today we've had Initial Jobless Claims for the week ending 1/9 (+7k to 284k, stronger than expected), and December's Import Prices ex-oil (-1.2%) & export prices (-1.1%). Ahead we'll have a $13 billion 30-year Treasury auction, so if you have some spare change step right up! We closed Wednesday with the 10-year sitting at 2.07% and this morning, after the news, we're at 2.09% but agency MBS prices haven't budged much yet since yesterday's close.


Jobs and Announcements

Motivity Solutions has a number of exciting opportunities in their expanding sales, marketing, and business development support team. Motivity has openings for Regional Sales Coordinators who play an important role in maintaining productive relationships with prospects, data management, and delivering a high-level customer experience. This position requires excellent organizational, administrative and communication skills. Motivity Solutions is the mortgage industry's leading business intelligence provider and has been continually recognized as one of the industry's top technology firms and one of Colorado's top private companies. Its flagship product, Movation, has become the industry standard for mortgage business intelligence, and has one of the fastest-growing user communities in the industry. For more information about the company, and to apply, click on this link or email HR Director Katy Klabon.

An established Orange County Mortgage Banker licensed in 20+ states is seeking a Funding Manager to support the company growth. "We have been instrumental in helping tens of thousands of homeowners and investors with their unique financing needs. We are a direct lender and handle the entire loan process in-house from origination to close of escrow. As a Fannie Mae Seller Servicer, FHA DE, and VA Automatic lender, we are well positioned for growth and expansion in 2016. The ideal candidate will have diverse Funding Management experience, and be responsible for managing an experienced team of Funders from Docs to Delivery. The ideal candidate should have experience to ensure ongoing training and compliance of the team, maintain a high level of customer service with our business partners, and be hands-on as necessary to effectively manage the work load to meet or exceed established service levels." Confidential inquiries should be sent to me at rchrisman@robchrisman. com.

XINNIX is hiring. Due to the overwhelming demand for the training services of XINNIX and The Mortgage Academy (Recruiting Workshops, Purchase Workshops, IGNITE, EDGE Online Series, etc.), XINNIX is currently conducting a search to fill several key positions. Leadership is seeking Sales and Leadership Trainers, Course Developers as well as Client Advisors (Inside Sales) "who demonstrate the standard of excellence XINNIX is known for throughout the industry. Founded in 2002 and headquartered in Atlanta, Georgia, XINNIX provides the mortgage industry's most effective and energizing sales and leadership training programs. XINNIX has demonstrated an exceptional track record of success by helping mortgage companies across the nation experience incredible recruiting success, a measurable increase in purchase production and a growth in market share." The National Association of Business Resources named XINNIX one of Atlanta's "Best & Brightest Companies to Work For" in 2012, 2013, 2014 and 2015. Click on the link above or submit resumes to Sarah Federico.

Assurance Financial, Baton Rouge, Louisiana, is hiring branch managers and MLOs across the Southeast and Southwest. This is a great opportunity for anyone wanting to open a branch in an environment where they can substantially increase their personal and branch production. The company is aggressively expanding into Colorado, Arizona, New Mexico, Louisiana, Texas, Mississippi, Alabama, Tennessee, Florida, Georgia, Arkansas, North Carolina and South Carolina. Assurance Financial is an established full-service mortgage banker with a 15-year history of consistently closing loans on time. Paul Peters, CMB, Sales Recruiting Manager, says loan officers joining Assurance experience a sizeable increase in income without extra work. For more information, contact Paul Peters.

And Ditech, which made mortgage headlines a few weeks ago on the retail side by shuttering that group, is reminding the industry that on the correspondent side it is seeing "exceptional growth" and in fact is expanding the services it offers to a larger number of correspondent clients by focusing on the non-delegated lending space. Congratulations to John Dubisky, Sales Director for the Eastern Region of the U.S. setting sales strategies and drive new business development, and Marcy MacDonnell, Sales Director for the Western Region of the U.S. increasing new business and build brand awareness. Ditech is offering non-delegated options helps to alleviate risks associated with delegated authority, allowing Ditech's experienced underwriting staff to securely handle the process.