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#2087992 - 07/14/16 03:36 PM Pre-Close Reviews?
Cheli Offline
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Cheli
Joined: May 2013
Posts: 919
Hi- Does anyone perform a Pre-Close "Review" of a mortgage loan closing package?
Ie: dates correct, all necessary documents are included, correct forms used etc??

As a compliance officer, I do perform this because frankly, our LOS is horrible, and staff is not retaining much of their training (another issue I battle on daily basis)...
but it is getting beyond tedious - However, we are heading in a new direction with a new LOS, and there is a lot of "trust" that is going into the new LOS...
The goal is to not have to perform "pre-close reviews" and trust the system; deficiencies can be caught in audits. Ultimately removing me from the front end (proactive, spear-head) process and placing me in an auditing (advising) role.

Ideally, they want to see the entire review go away...even once a new LOS has established some trust, would anyone agree that a Review should still be performed?...perhaps just more high level by the actual department?

Thoughts?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2088006 - 07/14/16 03:54 PM Re: Pre-Close Reviews? Cheli
MScarn6942 Offline
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Land Lacking in Lakes, IL
I used to do those at my previous bank, not so much to proof the LOS (pre-TRID, the LOS was fine), but to proof the processors. We had tons of secondary market exceptions that had to be cleared on lots of loans, so I did some of the proofing to make sure the package that went out was correct and that we at least wouldn't have to have the borrower resign.
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#2088012 - 07/14/16 04:00 PM Re: Pre-Close Reviews? Cheli
Cheli Offline
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Proofing- I like that...Yes, with the reviews, I was given more responsibility to review not only for regulatory purposes but for additional investor requirements as well. Which, I have to add, I do still capture quite a few of those in a pre-close review. Thank you for your feed-back.

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#2088044 - 07/14/16 05:08 PM Re: Pre-Close Reviews? Cheli
Truffle Royale Offline

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We pre and post closing review here. And we just got a new highly compliant trust worthy LOS too. But no LOS system can catch the misspelling on the legal that I did just the other day. and it was big enough that the investor would have undoubtedly kicked it back. We're not going to be stopping that process any time soon either...not as long as garbage in still equals garbage out.

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#2088084 - 07/14/16 07:02 PM Re: Pre-Close Reviews? Cheli
Cheli Offline
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Cheli
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That's my concern, Truffle Royale...the training ie: garbage in = garbage out. Our team is really having a hard time retaining our procedures for TRID (well, over all everything at this point)... I think the department is imploding a bit...The training is on a day-to-day basis (I literally sit with individuals everyday and work through files from all different stages of the loans), along with group trainings...So, to still see errors (ie: the right of rescission dates being incorrect o.m.g)...I don't think a pre-review should stop...but, quite a bit of push for it to stop...

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#2088098 - 07/14/16 07:53 PM Re: Pre-Close Reviews? Cheli
JWills, CRCM Online
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JWills, CRCM
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The Mitten State
Cheli, we have the same issue here. We did put in place a pre closing worksheet and our mortgage department is supposed to be do this, it flows from the time of application to either the loan closing/denial/withdrawal. We still find a lot of issues. When TRID came into play, and our new LOS, they were told to 'test, test' test', but they kept stating they were too busy. That did nothing but backfire for them. We do the pre-closing, and also a secondary review is done after the loan closes. Somedays we would like to beat our heads against the wall.
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#2088102 - 07/14/16 08:02 PM Re: Pre-Close Reviews? Cheli
RR Joker Offline
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The Swamp
Pre-close review here on TRID loans. Wish they'd do it on EVERYTHING! laugh!
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#2088124 - 07/14/16 09:15 PM Re: Pre-Close Reviews? Cheli
danaken Offline
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Posts: 88
OK
We do pre-close and post-close reviews. We don't have much volume, but I am basically working one on one with a doc prep person because each deal we do seems to have something quirky, so nothing has been black & white. The other doc prep person has refused to touch them. Apparently our department has imploded!

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#2088126 - 07/14/16 09:20 PM Re: Pre-Close Reviews? Cheli
ahkcompliance Offline
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Joined: Sep 2008
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Midwest
Pre-close review on TRID loans as well. For some, I review LEs before we issue also.

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#2088127 - 07/14/16 09:22 PM Re: Pre-Close Reviews? Cheli
raitchjay Online
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Pre-close (including a review of TRID earlies before they go out) and post-close review of every RE loan we make, whether TRID or not.
Last edited by raitchjay; 07/14/16 09:23 PM.
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#2088129 - 07/14/16 09:26 PM Re: Pre-Close Reviews? Cheli
ScoutLaRue Offline
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Joined: Jul 2016
Posts: 73
I'm new to this position, but I plan to start pre-closing review on a select number of files each month when I get caught up. This was a part of my previous job role, and it did help to identify trends in processing and underwriting. We don't have much volume here either so after post closing and my other duties are complete, I hope to fit a few in a month.

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#2088140 - 07/14/16 10:01 PM Re: Pre-Close Reviews? Cheli
Cheli Offline
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Cheli
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Wow- Thank you so much for all of the responses! ...So it seems I am not off-kilter for my pushing back to really keep this step within the process with the Mortgage Dept. I'll fight the good fight on this one...Thank you so much everyone!

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#2088222 - 07/15/16 02:24 PM Re: Pre-Close Reviews? Cheli
Jen J Offline
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Cheli, you may already be doing this, but I think the best defense on keeping a pre- or post-review in place is to keep a running tally of the types of errors you are seeing. One institution I worked for felt there was no issues with mortgage processing until I was able to show them the percentage of files with errors . . .

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#2088238 - 07/15/16 02:43 PM Re: Pre-Close Reviews? Cheli
Cheli Offline
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Cheli
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I send them an email, including management, on every issue...
:-o ;-)

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#2088246 - 07/15/16 02:53 PM Re: Pre-Close Reviews? Cheli
ScoutLaRue Offline
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Joined: Jul 2016
Posts: 73
Question for all on the subject of post closing & pre closing reviews...I am new to this role so I am still trying to decide on the best procedure..as there is not one set up here.

Do you meet with each individual when you see a trend, or send a general blanket email to all LOs/Processors stating general trends and findings?
Of course, I am still writing up a full detailed report for audit committee--however, I'm trying to decide how to address review findings on a regular basis.

Hope Cheli doesn't mind I hijacked the thread a bit!

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#2088248 - 07/15/16 02:59 PM Re: Pre-Close Reviews? Cheli
raitchjay Online
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If i see a trend (or an error that i think could become a trend, or just an issue i think is particularly important), i will verbally notify the involved processor and then often follow up with a blanket email to all discussing the issue. I wish i could say this makes those issues go away, but it doesn't....but it does improve the situation.
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#2088249 - 07/15/16 02:59 PM Re: Pre-Close Reviews? Cheli
MScarn6942 Offline
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Land Lacking in Lakes, IL
Scout, I think a blanket email can be useful, but nowhere near as useful as meeting one on one (or meeting with the employee and their manager). Blanket emails can tend to get ignored because they're seen as "not about me" or "someone else's problem". Just my opinion smile
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#2088253 - 07/15/16 03:07 PM Re: Pre-Close Reviews? Cheli
Cheli Offline
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Cheli
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I meet one on one with the individual...If it's a "trend" I speak with the manager first - Sometimes the manager prefers a meeting for round table discussion so I can explain more thorough and discuss further if need be, or the manager will basically "approve" an email blast...just depends on the severity of the rule, if they are neglecting procedures, if more obvious training is identified etc...
But my catch 22 is, that I have proven that we need this step in the process still, but the "support" to it is dwindling...It's odd...

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