Monday, February 19, 2007 - Texas Disclosures and Point 5.4 |
By Rachel McNamara
FIRST LET ME SAY....Do not skim over this post! There are some really crucial compliance details here!!!
I hope that by now, those of you who are living in the Calyx Point winter wonderland have received your update to version 5.4 from 5.3a. If you have not, you need to contact them about your subscription status.
Aside from the upgrades that they are more than happy to tell you about, I just wanted to make sure that you are using the correct forms since there are some very specific disclosures here in Texas that we have yet to see in Point, though I have requested it.
My advice is not to rely solely on the software for your compliance. This is a trap that I see many mortgage brokers fall into in the compliance consulting work that I do.
I tell the clients that I work for that they should not rely on the lenders or on the software for their compliance. Lenders are watching out for their own compliance and only very lightly monitor yours. I also see forms change and it takes a while for the software to catch up to the current forms. Be aware!
The best way to be aware is to stay current with your continuing education and also read the blog posts here. We are constantly updating our courses and blog site to give you the best and most current information.
Alliance Academy wants you to SUCCEED!
Okay, so here's what you need to know!
Texas Mortgage Broker Disclosure
- First, it should not allow "Company" to be an option because the state does not license companies. It only licenses individuals under the Texas Mortgage Broker License Act. Allowing this to be an option encourages people to be out of compliance, but for now, Point is still allowing it. The two options should be Mortgage Broker or Loan Officer.
- GLITCH: Only the use of "Loan Officer" will work for inserting the name of the licensed individual! If you check Company OR Mortgage Broker, it puts the company name in on the disclosure instead of the individual. It didn't work in 5.3 either.
- SOLUTION: Always check loan officer and make sure that your Master File Templates are saved that way too.
Texas Homestead Cash Out Disclosure a.k.a. "The 12 Day Letter"
- This is still not included in point, but you can download it here in English and Spanish.
Texas Multiple Roles Disclosure
- Again, this is still not included in point, but you can download it here for you to use, as needed.
Texas Pre-qualification/Pre-approval Letters
- The generic prequalification letter that is available in Point WILL NOT meet the guidelines of what is required by the state. Please make sure you are using the correct format.
Texas High Cost Loans - Here are the definitions and requires the specific disclosure of Texas High Cost Loans.
- Not that everyone out there is doing high cost loans, but surely a refresher might be good. Might want to just have them handy in case you ever come across the need for the document.
- Here is the disclosure in English and Spanish.
P.S. Don't forget to use the Conversation Log. It's so easy to cut and paste an email right into the software. Take advantage of it! This is a big topic in the SML audits. Start a new habit or refresh an old one today!!! |
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