Top 15 Mortgage QC Findings for 2018
The top 15 mortgage quality control issues in 2018, as compiled from tens of thousands of post-close QC audits that we performed over the past year, show lenders still struggling to consistently comply with enhanced disclosure requirements instituted by the Consumer Financial Protection Bureau (CFPB) in 2016.
In the third full year of the new requirements posed by the TILA-RESPA Integrated Disclosures (TRID) rule, our audits show three of them in the top 5 quality control findings, where they have been lodged from the beginning. The number of these regulatory issues remained steady in 2018 even as a decrease in the number of mortgages led to a drop in the volume of audits.
“Despite everyone’s understanding of TRID and efforts to correct for it, we’re not really seeing the improvement we should be seeing,” said Brady Meadows, Strategic Account Manager at MetaSource.
Meadows says the findings suggest that lenders may be juggling too many versions of documents as circumstances change, leading to lost or conflicting records. Some lenders, he said, reissue documents for every small change, creating multiple re-disclosures “when it’s not necessarily required.” he said.
|1||Closing Disclosure – Tolerance Violation|
|2||Closing Disclosure – Calculating Cash to Close|
|3||Intent to Proceed – Missing or Defective|
|4||Closing Disclosure – Timing Violation|
|5||Incorrect Income Calculation|
|6||Loan Estimate – Timing Violation|
|7||Insufficient Assets to Close|
|8||Verification of Employment – Missing or Defective|
|9||Settlement Service Provider List – Missing or Defective|
|10||Security Instrument – Missing or Defective|
|11||DU or AUS Findings Report – Missing or Defective|
|12||Omission of Debts – Unacceptable|
|13||Income Documentation – Insufficient|
|14||Total Points and Fees – Exceeds Maximum|
|15||VA Certificate of Loan Disbursement – Missing or Defective|
If you are struggling to maintain compliance with TILA-RESPA requirements or would like help in developing strategies to improve your compliance, call the industry-leading experts at MetaSource today. We can even audit your internal auditors to see how they’re doing.