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#1931253 - 06/10/14 10:10 PM
Waiving ATR current employment status verification
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Joined: Dec 2006
Posts: 435
TN
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One of the 8 factors to consider for ATR compliance is the applicant’s current employment status, if you need and are using income from employment for qualifying purposes. I’m of the opinion that third-party verification of the current employment status is not something that can be waived. Also, in my opinion, use of W-2s or paystubs, which verify amount of income, are not sufficient to verify current employment status.
Now, after everything we’ve gone through in recent months to put policies and procedures in place, I have those who think it’s OK to waive those because there is a cost involved for some of the larger employers. I’d like to hear what others have to say.
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#1931297 - 06/11/14 01:14 PM
Re: Waiving ATR current employment status verification
Sewanee, CRCM
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Cape Cod
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I understand that those who feel constrained by the ATR requirements, including verification of employment, feel that those rules may disqualify some applicants, thus affecting the loan originator's income.
Frankly, short memories are often what puts lending and regulation on their pendulum swings from bad to good and back again. It's time to understand that loose underwriting "standards" were part of the problem that resulted in the bursting of the real estate bubble in 2008, the worst recession in most Americans' memories, and the current more rigid regulatory environment.
Would those jokers prefer to sneak in one more borrower on the margin and make a couple of extra bucks, or be back on unemployment?
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John S. Burnett
BankersOnline.com
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#1931743 - 06/12/14 12:12 AM
Re: Waiving ATR current employment status verification
John Burnett
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Joined: Dec 2006
Posts: 435
TN
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I understand that those who feel constrained by the ATR requirements, including verification of employment, feel that those rules may disqualify some applicants, thus affecting the loan originator's income.
Frankly, short memories are often what puts lending and regulation on their pendulum swings from bad to good and back again. It's time to understand that loose underwriting "standards" were part of the problem that resulted in the bursting of the real estate bubble in 2008, the worst recession in most Americans' memories, and the current more rigid regulatory environment.
Would those jokers prefer to sneak in one more borrower on the margin and make a couple of extra bucks, or be back on unemployment? John, I wish I thought this was the motivation behind the action. Unfortunately, I believe this is a case of "I don't like the rule, I think it doesn't make any sense, so I just won't follow the rule." Additional conversations are to follow, so should make for an interesting week. Thanks for the input.
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#1931762 - 06/12/14 12:38 PM
Re: Waiving ATR current employment status verification
Sewanee, CRCM
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sewanee, you are probably spot on in your thinking.  I had in-house council make a similar comment the other day. Community bank's in particular have a really tuff time with this concept...it's just not how they have operated and almost without fail know their customers and where they work, live and play. For them, it should be simple. No we won't, yes we will, or WHY did I DO that!!!
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#1932089 - 06/12/14 07:58 PM
Re: Waiving ATR current employment status verification
Sewanee, CRCM
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Sewanee and RR -- I think you're probably right. On the other hand, if we got rid of all the requirements that we don't like and don't think make sense ....
Life would be a lot sweeter, but a lot of Compliance Officers would be looking for work.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1932099 - 06/12/14 08:10 PM
Re: Waiving ATR current employment status verification
Sewanee, CRCM
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The Swamp
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Darn tooten! Oh..and when I said, "for them, it should be simple"...that almost sounds like I think they should be able to play by different rules. Absolutely not my intention! 
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