Am I the only one that is having trouble getting AUS and AUS result correct?

If I correctly interpreted the language in the August update by the CFPB, they indicated if an FHA loan is submitted through DU to TOTAL scorecard we need to report TOTAL. According to the filing instructions if you use TOTAL you should either be reporting Accept or Refer for the AUS decision. When I am looking at the findings we get back using DU/TOTAL the recommendation indicated by DU is Approve/Eligible and not Accept.

Any comments on what others are doing or how they have interpreted it would be appreciated.

The AUS waterfall also gives me a headache

Yes...following this...this is a source of complete confusion in this reg!

So glad to hear that I'm not the only one struggling with the AUS reporting.

I'm following as well. If you have a conventional loan and you run it through DU 6 times, do you report 4 of them? Or, do we only report more than one if submission #1 was FHA, submission #2 was Conventional 30 year, submission #3 Conventional 20 year? The loan type / Term would have to be different to report more than one?

BA13, my understanding is that you would report your final. You only report multiple (iv) if your situation doesn't meet any of the waterfall scenarios.


If a financial institution obtains two or more AUS results and the AUS generating one of those results corresponds to the loan type reported pursuant to § 1003.4(a)(2), the financial institution complies with § 1003.4(a)(35) by reporting that AUS name and result. For example, if a financial institution evaluates an application using the Federal Housing Administration's (FHA) Technology Open to Approved Lenders (TOTAL) Scorecard and subsequently evaluates the application with an AUS used to determine eligibility for a non-FHA loan, but ultimately originates an FHA loan, the financial institution complies with § 1003.4(a)(35) by reporting TOTAL Scorecard and the result generated by that system. If a financial institution obtains two or more AUS results and more than one of those AUS results is generated by a system that corresponds to the loan type reported pursuant to § 1003.4(a)(2), the financial institution identifies which AUS result should be reported by following the principle set forth below in comment 4(a)(35)-3.ii.


ii. If a financial institution obtains two or more AUS results and the AUS generating one of those results corresponds to the purchaser, insurer, or guarantor, if any, the financial institution complies with § 1003.4(a)(35) by reporting that AUS name and result. For example, if a financial institution evaluates an application with the AUS of Securitizer A and subsequently evaluates the application with the AUS of Securitizer B, but the financial institution ultimately originates a covered loan that it sells within the same calendar year to Securitizer A, the financial institution complies with § 1003.4(a)(35) by reporting the name of Securitizer A's AUS and the result generated by that system. If a financial institution obtains two or more AUS results and more than one of those AUS results is generated by a system that corresponds to the purchaser, insurer, or guarantor, if any, the financial institution identifies which AUS result should be reported by following the principle set forth below in comment 4(a)(35)-3.iii.


iii. If a financial institution obtains two or more AUS results and none of the systems generating those results correspond to the purchaser, insurer, or guarantor, if any, or the financial institution is following this principle because more than one AUS result is generated by a system that corresponds to either the loan type or the purchaser, insurer, or guarantor, the financial institution complies with § 1003.4(a)(35) by reporting the AUS result generated closest in time to the credit decision and the name of the AUS that generated that result. For example, if a financial institution evaluates an application with the AUS of Securitizer A, subsequently again evaluates the application with Securitizer A's AUS, the financial institution complies with § 1003.4(a)(35) by reporting the name of Securitizer A's AUS and the second AUS result. Similarly, if a financial institution obtains a result from an AUS that requires the financial institution to underwrite the loan manually, but the financial institution subsequently processes the application through a different AUS that also generates a result, the financial institution complies with § 1003.4(a)(35) by reporting the name of the second AUS that it used to evaluate the application and the AUS result generated by that system.


iv. If a financial institution obtains two or more AUS results at the same time and the principles in comment 4(a)(35)-3.i through .iii do not apply, the financial institution complies with § 1003.4(a)(35) by reporting the name of all of the AUSs used by the financial institution to evaluate the application and the results generated by each of those systems. For example, if a financial institution simultaneously evaluates an application with the AUS of Securitizer A and the AUS of Securitizer B, the financial institution complies with § 1003.4(a)(35) by reporting the name of both Securitizer A's AUS and Securitizer B's AUS and the results generated by each of those systems. In any event, however, the financial institution does not report more than five AUSs and five results. If more than five AUSs and five results meet the criteria in this principle, the financial institution complies with § 1003.4(a)(35) by choosing any five among them to report.

I need clarification for the following: We have not submitted an application with our secondary market but we might use the AUS on the website to see if it can be submitted. If the AUS denies the application but we do not submit secondary market and we send the denial then do we have to report the AUS. We might not use the reasons documented on the AUS for our denial process for an in-house loan application.

i. A financial institution that uses an AUS, as defined in § 1003.4(a)(35)(ii), to evaluate an application, must report the name of the AUS used by the financial institution to evaluate the application and the result generated by that system, regardless of whether the AUS was used in its underwriting process. For example, if a financial institution uses an AUS to evaluate an application prior to submitting the application through its underwriting process, the financial institution complies with § 1003.4(a)(35) by reporting the name of the AUS it used to evaluate the application and the result generated by that system.

That's what I was afraid of just trying to see if there might be a gray area. Thank you.

I have seen quite a few presentations indicating report multiple AUS and results if none of the rules apply but that wasn't how I interpreted the rule. I read the rule that you only report multiple when you run multiple AUS results simultaneously - such as DU and LP were both run at noon on the same day.

The language from the rule for multiple AUS results indicates: iv. If a financial institution obtains two or more AUS results at the same time and the principles in comment 4(a)(35)-3.i through .iii do not apply, the financial institution complies with § 1003.4(a)(35) by reporting the name of all of the AUSs used by the financial institution to evaluate the application and the results generated by each of those systems.

To me the language above states if multiple AUS results are obtained simultaneously (both run at noon the same day) and (not or) the principles in comment 4(a)(35)-3.i through .iii do not apply, then report multiple AUS systems.

I think it's making a bit more sense but have a scenario I'd like run past you all.

We ran a FHA loan type through FNMA DU. FNMA DU includes the TOTAL Scorecard for FHA loans. Do we report the AUS as DU or TOTAL Scorecard? I think DU as that's the scrutinizer used. Correct?

I am also interested in the FNMA DU/TOTAL Scorecard scenario posted by BA13.

To add another wrinkle....if you initially ran FNMA DU that includes TOTAL Scorecard for an FHA loan request, then the loan switches to conventional and you then run FNMA DU, do you only report FNMA DU because that AUS matches the final loan type of conventional?

My understanding is you have to report TOTAL for DU runs on an FHA loan. If you switch to conventional and rerun DU, then you would only report DU.

"If a financial institution obtains two or more AUS results and the AUS generating one of those results corresponds to the loan type reported pursuant to § 1003.4(a)(2), the financial institution complies with § 1003.4(a)(35) by reporting that AUS name and result. For example, if a financial institution evaluates an application using the Federal Housing Administration's (FHA) Technology Open to Approved Lenders (TOTAL) Scorecard and subsequently evaluates the application with an AUS used to determine eligibility for a non-FHA loan, but ultimately originates an FHA loan, the financial institution complies with § 1003.4(a)(35) by reporting TOTAL Scorecard and the result generated by that system."