Top 15 Mortgage QC Findings for 2017
With 2017 behind us, here is a look back at the top 15 mortgage quality control issues based on tens of thousands of post-close QC audits that we performed over the past year.
In their second full year of adjusting to the Consumer Financial Protection Bureau’s (CFPB) enhanced disclosure requirements, lenders managed a better track record of compliance. Only six of the top 15 findings were related to the TILA-RESPA Integrated Disclosures (TRID) rule, down from 12 of 15 in 2016, the first full year of the rule’s implementation.
Even so, the results suggest that lenders are still in the learning curve as TRID defects accounted for the top six findings on the list.
| Rank | Finding |
|---|---|
| 1 | Closing Disclosure – Tolerance Violation |
| 2 | Closing Disclosure – Calculating Cash to Close |
| 3 | Closing Disclosure – Timing Violation |
| 4 | Verification of Employment – Missing or Defective |
| 5 | Loan Estimate – Timing Violation |
| 6 | Incorrect Income Calculation |
| 7 | Insufficient Assets to Close |
| 8 | Security Instrument – Missing or Defective |
| 9 | Note – Missing or Defective |
| 10 | Mortgage Insurance Certificate – Missing or Defective |
| 11 | DU or AUS Findings Report – Missing or Defective |
| 12 | Total Points and Fees – Exceeds Maximum |
| 13 | Minimum Borrower Investment |
| 14 | Income Documentation – Insufficient |
| 15 | Closing Disclosure – Demand Features |
If you have issues with any of the above mortgage compliance defects or findings, or don’t know if you do, let us know. We can even audit your internal auditors to see how they’re doing.