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#2234834 - 04/15/20 02:33 PM
New URLA Delayed
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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Hot off the press for you secondary market lenders:
The new mandate date for the use of the redesigned URLA and AUS specifications is March 1, 2021.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2241687 - 08/27/20 06:48 PM
Re: New URLA Delayed
rlcarey
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Platinum Poster
Joined: Dec 2008
Posts: 727
Tennessee
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Hey Randy....I understand that the earliest date we can use the redesigned URLA is Jan 1,2021 for loans sold on the secondary market....
We want to use the redesigned URLA for our consumer lending division that does not sell loans on the secondary market....can we use it earlier than Jan 1, 2021 when the secondary market is not involved?
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#2241692 - 08/27/20 07:33 PM
Re: New URLA Delayed
rlcarey
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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Sure - you can use a napkin for a mortgage application on a portfolio loan if you want too, but why in the world would you want to use an application that is so complex for portfolio loans?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2241694 - 08/27/20 07:39 PM
Re: New URLA Delayed
rlcarey
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Platinum Poster
Joined: Dec 2008
Posts: 727
Tennessee
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That made me laugh...thanks....
I don't call the shots on the procedures...
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#2241703 - 08/27/20 09:04 PM
Re: New URLA Delayed
rlcarey
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10K Club
Joined: Oct 2000
Posts: 27,748
On the Net
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You use the term "complex" like it isn't the coolest thing since sliced bread, or several loaves of sliced bread, and mixed complicated slices of rye, marble, multi-grain, French and Italian because we want to incorporate everyone and all the ingredients we can, plus addendum's. :P
Honestly, the point deserves consideration by bank management as a cost-saving issue. And if it isn't considered now, I'll bet it is when the first insider applies for a Reg O mortgage.
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#2248997 - 02/10/21 03:47 PM
Re: New URLA Delayed
rlcarey
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100 Club
Joined: Apr 2015
Posts: 228
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Maybe an obvious question regarding applicability, but if our bank has a separate mortgage department that sells their loans to GSEs, only that department would be required to use the new URLA and our portfolio lenders can use our current form (or napkin or whatever), correct?
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#2248999 - 02/10/21 04:10 PM
Re: New URLA Delayed
rlcarey
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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Correct - a 1003 is purely a secondary market requirement.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2249423 - 02/19/21 02:07 PM
Re: New URLA Delayed
rlcarey
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Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
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We do very little secondary market lending as most of our mortgage loans are held in portfolio. We will use the new URLA for any secondary market loans sold but are going to continue to use the old 1003 for portfolio loans.
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#2249426 - 02/19/21 02:26 PM
Re: New URLA Delayed
rlcarey
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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The only thing I would think about is how are the demographics of your applicants split between your portfolio and secondary market applications? Having two different application processes might be of some concern, since the new URLA is so much harder to complete by an applicant.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2250781 - 03/17/21 11:35 PM
Re: New URLA Delayed
rlcarey
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Platinum Poster
Joined: Sep 2005
Posts: 746
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If we do not sell our loans can we continue to use the old urla?
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#2250786 - 03/18/21 11:23 AM
Re: New URLA Delayed
rlcarey
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Power Poster
Joined: Sep 2010
Posts: 2,658
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Yes. If the loan will be a portfolio loan and you never intend to sell it, the old URLA is sufficient. The reason for this is that the URLA is a Fannie/Freddie (secondary market) requirement. The only application requirements (to actually have a written application) are found in Regulation B, which does not specifically require a certain application. That said, it certainly isn't a bad idea to use the new URLA, even if you don't sell your loans.
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Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2250788 - 03/18/21 11:40 AM
Re: New URLA Delayed
rlcarey
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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That said, it certainly isn't a bad idea to use the new URLA, even if you don't sell your loans. Adam - have you seen the new URLA?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2250791 - 03/18/21 11:58 AM
Re: New URLA Delayed
rlcarey
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Power Poster
Joined: Sep 2010
Posts: 2,658
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I know, Randy.
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Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2251046 - 03/23/21 06:00 PM
Re: New URLA Delayed
rlcarey
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Diamond Poster
Joined: Oct 2015
Posts: 1,668
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Could an issue with using the old URLA is it is technically an expired form? I understand there is no specific application requirement for ECOA, but I worry about using a specifically issued form that is expired.
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#2251047 - 03/23/21 06:09 PM
Re: New URLA Delayed
rlcarey
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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Expired according to whom? If you have a form that you developed internally - when would that expire? You can use a napkin for a mortgage application if you want too as long as you do not plan on selling the loan into the secondary market.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2251062 - 03/23/21 08:04 PM
Re: New URLA Delayed
rlcarey
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Diamond Poster
Joined: Oct 2015
Posts: 1,668
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Yes, if it was a form developed internally. But, it's not.
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#2251075 - 03/23/21 09:15 PM
Re: New URLA Delayed
rlcarey
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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The old form still complies with Regulation B which is your most pressing issue on an application form.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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