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#2234834 - 04/15/20 02:33 PM New URLA Delayed
rlcarey Offline
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rlcarey
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Galveston, TX
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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#2241687 - 08/27/20 06:48 PM Re: New URLA Delayed rlcarey
Compliance504 Offline
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Tennessee
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
rlcarey Offline
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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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#2241694 - 08/27/20 07:39 PM Re: New URLA Delayed rlcarey
Compliance504 Offline
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Tennessee
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
Andy_Z Offline
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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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#2248997 - 02/10/21 03:47 PM Re: New URLA Delayed rlcarey
deltacrcm Offline
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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
rlcarey Offline
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Correct - a 1003 is purely a secondary market requirement.
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#2249423 - 02/19/21 02:07 PM Re: New URLA Delayed rlcarey
ahkcompliance Offline
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Midwest
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
rlcarey Offline
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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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#2250781 - 03/17/21 11:35 PM Re: New URLA Delayed rlcarey
theloanbug Offline
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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
Adam Witmer Offline
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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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#2250788 - 03/18/21 11:40 AM Re: New URLA Delayed rlcarey
rlcarey Offline
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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? laugh
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#2250791 - 03/18/21 11:58 AM Re: New URLA Delayed rlcarey
Adam Witmer Offline
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I know, Randy. wink
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#2251046 - 03/23/21 06:00 PM Re: New URLA Delayed rlcarey
Compliance NABW Offline
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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
rlcarey Offline
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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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#2251062 - 03/23/21 08:04 PM Re: New URLA Delayed rlcarey
Compliance NABW Offline
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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
rlcarey Offline
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Galveston, TX
The old form still complies with Regulation B which is your most pressing issue on an application form.
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