I just conducted staff training on some of the mortgage changes coming in January (notably the ATR rules).

It's been a while since I've seen that many blank stares. I think they are blaming me for the new rules.

Our main real estate loan officer has been working with me on all the new changes. Helping with worksheets and attending training. So she should be in good shape. It's the others that will give blank stares and will just say "Let Lisa do all the real estate loans!"

Same as Queen. We only have 3 RE lenders and they have been involved with most of the trainings. Just trying to get as many tools as possible to help them.

I'm seriously laughing. I just did a conference call with our lenders, and the dead space was deafening. Their boss actually just scheduled a follow-up meeting for next week so that they can review the handout I provided, and come up with questions.

Y'all are scaring me. I'm going to be rolling it out later this week. I'm sure the lenders will say it is the job of the processors and the processors will say it is the lender's job.

Ugh.

Unfortunately our vender has not updated or system yet. We will be training last minute in order to make time to review our lending program updates and update our procedures. I am relying heavily on our back office processors and underwriters to check and double check the files until our lenders get used to the new requirements.

I am just documenting everything we are doing to prepare for this!

The thing that threw my people was when I tried to explain the difference between the standard ATR and the QM. Using the phrase "conclusive presumption of compliance" will instantly take them from "huh" to "uhh".

Just decide what type of loans your FI wants to make and explain it that way.

Our vendor has not updated yet either. I have been working with our Mortgage Department staff and our Mortgage Loan officer on the changes. We have had a couple of webinars, and lots of handouts They will be the ones that will have to work with it, not our loan officers, heaven forbid! Our loan officers are not forced to be responsible for much. That is sad.

Our vendor updated and the deed I prepared today for a closing had all the NMLS info on it. Some of their updates did not function correctly and a new release is scheduled this week (I think).

ETA: and the note too!

We introduced an initial high level powerpoint training on ATR/QM, Homeownership Counseling, Appraisals for higher priced loans and on Appraisal changes due to ECOA today... it seemed to go over well and they actually seemed receptive! I think that since we have decided that non-QM loans can be and are good loans we are interested in (with sound underwriting and character), they are comfortable knowing that there will still be lots of opportunities for good loans going forward.

We anticipate getting our changes from Easy Lender tomorrow, and hopefully into the test bank by the end of the week for testing and to develope the techinical side of the training for later this month.

Our Residential Department was trained starting in October (their manager is awesome!)and we started with Consumer Lenders last week. Lots of deer-in-the-headlight looks.

Part of their training last week and this week (have 75+/-) to training, and will continue first week of January.

Our LOS vendor will not have the new release available with all the required updates and changes until next week! We have to test everything, then when we were looking to set up a training date we realized half the bank (it seems!) is on vacation sometime during the last two weeks of the year over the holidays. So we have to train on January 2, then hope we covered everything and everything works (ha ha)..... We have, however, been updating the lenders and processors on the new rules, requirements, etc., just haven't been able to show them anything specific until our vendor is ready. Very frustrating to say the least. Management has sent an indict out that if need be, mortgage lending will be suspended on January 10 if we are not able to be 100% compliant with the new rules.

Which LOS vendor Bike4life? Our vendor is MortgageFlex and they too have not delievered the final update. Ugh!

I wonder if a lot of them are banking on a delay. My mortgage sub manager seems to think there may be a delay until 2015 but I'm telling him he is nuts.

We use Jack Henry, and I have been told that there is an update in the works, just not sure when it will happen. Hopefully soon!

Cordray has specifically said there won't be a delay.

It appears we are headed down the same path we took when the GFE was changed the last time. Everybody expected HUD to extend the effective date, so few were ready when HUD decided not to extend it.
I think we are in that scenario now and there will be no extension. If they have to put it off, it will be view as another government failure.

I agree with you!

I'm curious as to what software updates you are waiting or expecting except for the points and fees calculation. The majority of the new process will be the collection and verification of third party data.

That is nothing new to us... that is just prudent underwriting we have done for years. A few more items maybe, but nothing really different there other than segregating it differently within the file/efile.

Agree! Not really much difference for us as well. Just a few things and more documentation related than anything. Our policy/procedures already capture the 8 ATR requirements. Our vendor will have a way to help document ATR/QM rules but the end user ultimatly will need to know which QM we qualify for.

Our system is to be updated next week...the first release had a glitch in the ATR/QM section. The ATR portion worked, but not the QM, so it's a technical fix really. Everything else appears to be in order. However, getting the processors to comprehend it remains to be seen.

Our first-round training is scheduled for next week. I expect to see grumbling and dropped-jaws.

I also plan on being $1.00 richer on the 10th as I have a bet with the CEO that there will be no delays. If he was all that confident, maybe I could have squeezed more out of him.