NMLS MCR Enhancements

Transcription

1 NMLS MCR Enhancements Belw are the changes t the NMLS Mrtgage Call Reprt (MCR) that will be incrprated int the NMLS release, scheduled fr January 26, Althugh these enhancements will be included in NMLS release , their implementatin and enfrcement will be staggered thrughut the year. Users will first see these changes available n April 1, 2015 the first day a user may create a Q filing. The changes belw will affect the Residential Mrtgage Lan Activity Reprt (RMLA) fr Standard filers and bth the RMLA and the Financial Cnditin (FC) fr Expanded filers. Please review the changes as they may relate t the submissin f Q data, and subsequent MCR filings. If yu have any additinal questins, please refer t the NMLS Resurce Center r cntact the NMLS Call Center at NMLS-123 ( ). Qualified Mrtgage (QM) Fields Included in NMLS release is the additin Qualified Mrtgage (QM) fields. These new data fields will require filers t reprt the number and dllar amunt f Qualified Mrtgage (QM) and Nn-QM lans n the state-specific RMLA and cmpany Financial Cnditin sectin (FC). All cmpanies cmpleting the MCR will be required t submit amunt and cunt infrmatin n general QM status f clsed and funded lans n the state specific RMLA, as well as the held fr investment (HFI) value f these lans n the FC. QM and nn-qm lan reprting will be system enfrced starting with the first quarter 2015 MCR filings. Qualified Mrtgage (QM) (AC920) Standard and Expanded Nn-Qualified Mrtgage (AC930) Standard and Expanded New data entry fields (Expanded nly): Qualified Mrtgage (QM) (A060W1) Expanded Nn-Qualified Mrtgage (A060W2) Expanded New calculated fields: Ttal QM and Nn-QM (AC990) Standard and Expanded Ttal Lans (A060W9) Expanded Natinwide Servicing and New State Specific Servicing Fields The additin f natinwide servicing infrmatin fields will be integrated int the Cmpany-level RMLA fr all MCR filers - Expanded and Standard, t reprt, as well as additinal state-specific servicing infrmatin fr all Expanded filers t reprt. The reprting f natinwide servicing data will be system enfrced fr all filers starting with the first quarter 2015 MCR filings and fr Expanded filers fr state specific servicing infrmatin. Whlly Owned Lans Serviced (LS010) Standard and Expanded Lans Serviced Under MSRs (LS020) Standard and Expanded Subservicing fr Others (LS030) Standard and Expanded

2 Subservicing by Others (LS040) Standard and Expanded Lan Servicing Transferred In During the Perid (LS100) Standard and Expanded Lan Servicing Transferred Out During the Perid (LS110) Standard and Expanded Less than 30 Days Delinquent (includes lans that are nt delinquent) (LS200) Standard and Expanded 30 t 60 Days Delinquent (LS210) Standard and Expanded 61 t 90 Days Delinquent (LS220) Standard and Expanded 91 r mre Days Delinquent (LS230) Standard and Expanded Clsed Lans with Servicing Retained During the Quarter (AC1200) Standard and Expanded Clsed Lans with Servicing Released During the Quarter (AC1210) Standard and Expanded New data entry fields (Expanded nly): Whlly Owned Lans Serviced (S510) Expanded Lans Serviced Under MSRs (S520) Expanded Subservicing fr Others (S530) Expanded Subservicing by Others (S540) Expanded Fixed Lans Serviced (S600) Expanded ARM Lans Serviced (S610) Expanded Gvernment (FHA/VA/RHS) Lans Serviced (S700) Expanded Prime Cnfrming Lans Serviced (S710) Expanded Prime Nn-Cnfrming Lans Serviced (S720) Expanded Other Lans Serviced (S730) Expanded Clsed-End Secnd Mrtgages Lans Serviced (S800) Expanded Funded HELOCs Lans Serviced (S810) Expanded Reverse Mrtgages Lans Serviced (S820) Expanded Cmmercial Mrtgage Lans Serviced (S830) Expanded Other Lans Serviced (S840) Expanded Equals 60% r less (S1000) Expanded Greater than 60% but less than r equal t 70% (S1010) Expanded Greater than 70% but less than r equal t 80% (S1020) Expanded Greater than 80% but less than r equal t 90% (S1030) Expanded Greater than 90% but less than r equal t 100% (S1040) Expanded Greater than 100% (S1050) Expanded NMLS ID, Owner Name, Pl #, UPB, and Lan Cunt (S520A) Expanded NMLS ID, Owner Name, Pl #, UPB, and Lan Cunt (S530A) Expanded NMLS ID, Servicer Name, Pl #, UPB, and Lan Cunt (S540A) Expanded New calculated fields (Standard and Expanded): Ttal Servicing Activity (LS090) Standard and Expanded Ttal Lans Transferred In and Out During the Perid (LS190) Standard and Expanded Ttal Lans Serviced (LS290) Standard and Expanded Ttal Clsed Lans (AC1290) Standard and Expanded New calculated fields (Expanded nly): Ttals Lans Serviced (S590) Expanded Ttal Rate Type (S690) Expanded Ttal Residential First Mrtgage Lans Serviced (S790) Expanded Ttal Other Mrtgage Lans Serviced (S890) Expanded

3 Ttal Mrtgages Serviced (S900) Expanded Ttal Mrtgages Serviced (S1090) Expanded Ttal Lans Serviced Under MSRs (S520TOT) Expanded Ttal Lans Serviced fr Others (Subservicing) (S530TOT) Expanded Ttal Lans Serviced by Others (S540TOT) Expanded Change in Applicatin Amunt Fields Fields t capture changes in applicatin amunt will be added t the Applicatin Data sectin f the Statespecific RMLA. All cmpany filers will be able t indicate the verall increase r decrease in the lan amunts frm an applicatin t the clsed lan, if applicable. These fields will be available fr reprting beginning the first quarter f 2015, but system enfrcement will be delayed until the first quarter f Net Changes in Applicatin Amunt (decreases shuld be reflected as negative) (AC065) Standard and Expanded New calculated fields (Standard and Expanded): Ttal Applicatin Pipeline (AC066) Standard and Expanded Ttal Applicatin Pipeline Results (AC090) Standard and Expanded New Warnings/Cmpleteness Checks New Warnings/Cmpleteness Checks (Standard) On the Standard RMLA-G a Cmpleteness Check will be added t require an Explanatry Nte if Data Warnings exist. New Warnings/Cmpleteness Checks (Standard and Expanded): Under RMLA Sectin 1 Applicatin Data, a data validatin warning will be added that a nte (ACNOTE) must be prvided if at least ne warning appears n the filing. This warning will be applicable t bth Standard and Expanded filers. Under RMLA Sectin 1 Clsed Lan Data, a cmpleteness check will be added t verify that amunt and cunt f Ttal Lan Type - Reverse Mrtgages (AC790_ 1_T / AC790_2_T, AC790_ 3_T / AC790_4_T, AC790_ 5_T / AC790_6_T) must equal Ttal Purpse f Reverse Mrtgage (AC890_1_T / AC890_2_T, AC890_3_T / AC890_4_T, AC890_5_T / AC890_6_T) respectively. This cmpleteness check will be applicable t bth Standard and Expanded filers. Under RMLA Sectin 1 Applicatin Data, a data validatin warning will be added t verify that the amunt and cunt f the Ttal Applicatin Pipeline (AC066_1_T, AC066_2_T, AC066_1_T / AC066_2_T, AC066_3_T, AC066_4_T, AC066_3_T / AC066_4_T) must equal the amunt and cunt f Ttal Applicatin Pipeline Results (AC090_1_T, AC090_2_T, AC090_1_T / AC090_2_T, AC090_3_T, AC090_4_T, AC090_3_T / AC090_4_T) respectively. This warning will be applicable t bth Standard and Expanded filers. Under RMLA Sectin 1- MLO(s) a cmpleteness check will be added t verify that amunt and cunt f Lans Clsed and Funded equals the amunt and cunt f Ttal QM and Nn-QM

4 lans, which als equals the amunt and cunt f Ttal Clsed Lans under Mrtgage Lan Originatr Data sectin. (AC070_1_PD= (AC 490_1_T + AC490_3_T) = ACMLOTOT_2_T) and (AC070_2_C = (AC490_2_T + AC490_4_T) = ACMLOTOT_3_T). This cmpleteness check will be applicable t bth Standard and Expanded filers. Under RMLA Sectin 1- MLO(s) a cmpleteness check will be added t verify the amunt and cunt f Lans Clsed and Funded equals the amunt and cunt f Ttal Serviced Lans, which als equals the amunt and cunt f Ttal Clsed Lans under Mrtgage Lan Originatr Data sectin. (AC070_1_PD = AC1290_1_T = ACMLOTOT_2_T) and (AC070_2_C = AC1290_2_T = ACMLOTOT_3_T) This cmpleteness check will be applicable t bth Standard and Expanded filers. Under RMLA General, a data validatin warning will be added that a nte (NOTE) must be prvided if at least ne warning appears n the filing. This warning will be applicable t bth Standard and Expanded filers. New Warnings/Cmpleteness Checks (Expanded nly): On the Financial Cnditin, a cmpleteness check will be added t verify that Ttal Mrtgage Lans, UPB (befre adjustments) f HFI, at Amrtized Cst (A060W_3_T) equals Ttal Qualified and Nn-Qualified Mrtgages, HFI, at Amrtized Cst (A060W9_3_T). This cmpleteness check will be applicable t Expanded filers. On the Financial Cnditin, a cmpleteness check will be added t verify that Ttal Mrtgage Lans, UPB (befre adjustments) f HFI, at Fair Value (A060W_4_T) equals Ttal Qualified and Nn-Qualified Mrtgages, HFI, at Fair Value (A060W9_4_T). This cmpleteness check will be applicable t Expanded filers. NOTE: Data Warnings will nt prevent submissin f a FC, hwever, users must acknwledge that the warnings exist prir the marking a FC as Ready t Submit. Users must prvide an explanatin if they cntinue with the filing and the data validatin exists. Miscellaneus A "Fill blanks with zer buttn" and a "Save" buttn have been added t the tp f Schedule A, B, C and D f the Standard FC and t the tp f Schedule A, B, C, D and O f the Expanded FC. On the expanded versin f the MCR, the fllwing fields have been included in additin t thse utlined abve. These fields will be required fr reprting starting the first quarter f New data entry fields (Expanded nly): Mrtgage Lans Mdified Under HAMP (S115) Expanded Lans Paid Thrugh Shrt Sale (S460) Expanded New label n existing field (Expanded nly): Lan Mdificatins cmpleted (nn-hamp) (S110) Expanded Definitin f Applicatin

5 SRR is intrducing a clarified definitin f Applicatin t address the issue f varius definitins f applicatin in state and federal law. These varius definitins create challenges when cllecting lan riginatin infrmatin and cmparing the different reprting requirements and interpretatins f what cnstitutes an applicatin fr purpses f state, federal, and MCR purpses. The fllwing, revised definitin is ffered as guidance starting in the first quarter f Absent further guidance frm state regulatrs, this revised definitin will have full system enfrcement the first quarter f This will be applicable t all MCR filers - Expanded and Standard. An applicatin is an ral r written request fr an extensin f credit encumbering a 1-4 family residential prperty. Exclude any cmmercial/business/investment purpse encumbrances frm reprting. Include inquiries r Pre-Qualificatin requests that result in denial f credit. The applicatin date used is either (1.)The date n the initial 1003 with the brrwer s signature; (2) The date f an ral request fr extensin f credit, with deference t the initial1003; (3) Inquiries and Pre-Qualificatin requests, if declined, shuld use the denial date. Examples f requests that are cnsidered an applicatin fr the NMLS MCR include, but are nt limited t, purchase f wner ccupied 1-4 family residential prperties including 2nd hmes and vacatin hmes; cnstructin f 1-4 family residential prperties (as described abve) made directly t the cnsumer; nn-cmmercial liens n residential prperties (Lines f Credit shuld be reprted at maximum apprved credit line); preapprvals n item #1 even if a residential prperty has nt been identified; reverse mrtgages regardless f purpse; refinance lans n all f the abve; all requests fr extensins f credit t purchase residential prperty that result in the issuance f an ECOA ntice. The belw definitin f applicatin will be in use fr 2015 MCR reprting. An ral r written request fr a hme purchase lan, a hme imprvement lan, r a refinancing that is made in accrdance with prcedures used by a financial institutin fr the type f credit requested (Per Reg B). Examples f requests that are cnsidered an applicatin fr the NMLS MCR include, but are nt limited t, any HMDA reprtable applicatin, preapprval requests, request withut a prperty address, r requests which include access t the brrwer's credit infrmatin.