Phil Grossfield's Blog

A LITTLE EXTRA…

QM 3% Comp Rule – What’s Included? When is it Effective?

GFE CHANGES BEGINNING JANUARY 1
$799 Lender Fee – Effective for Jan 1 Uploaded Submissions
With all the compliance issues we as a lender face, the cost per loan has gone up extensively. Interbank is long overdue to increase its lender fee. This is effective for all loans uploaded on or after Jan 1.
Comp Plan QM Changes – Effective for Jan 1 Uploaded Submissions
Comp plans are being automatically modified (unless you manually do so) effective for all loans uploaded on or after Jan 1:
      (1)  Max Compensation 2.500%, and
      (2)  Flat Fees and Floors Eliminated.

      The portal is now open to allow manual changes to your Broker Comp Plan.
      Simply log into the portal using your Admin User ID and select
      “Broker Compensation Settings” under the “Tools” menu.

WHEN DO CHANGES TAKE EFFECT?
Simply put, your GFE MUST be correct when you upload the submission package. When you took the application and when you locked is irrelevant.

FOR EXAMPLE, let’s say you took a loan application on December 27th, registered the loan in the Interbank portal on December 28th, and locked the loan online on December 29th. Your processor then uploaded the submission package on January 2nd.  Because the submission package was uploaded in January, you are subject to your NEW JANUARY COMP PLAN AND OUR NEW $799 LENDER FEE. The fact your borrower signed an application in December and you locked in December is irrelevant…you are now subject to the new Jan comp plan and lender fee because you uploaded in January. If your GFE is incorrectly based on our old Lender Fee or on your 4th quarter comp then the GFE is a compliance violation and therefore your loan and your lock must be cancelled.
If this is not 100% clear then please let me know….

  QM Points and Fees Included

  QM Points and Fees Not Included

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