4 Ways To Overcome Fair Lending Obsolescence

Regulatory exams and intense scrutiny present challenges for today’s lenders as they work to properly execute fair lending compliance. The intense focus of the regulators, the difficulty of effectively collecting and analyzing the right data in a timely manner, and unclear standards can make fair lending compliance burdensome and complicated.

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In an attempt to minimize this burden while mitigating risks, many lenders have accumulated a variety of fair lending risk analytics tools and services to help them combat these issues, and compliance-related tasks are performed across a wider staff. However, juggling multiple fair lending tools, vendors and consultants has neither simplified nor improved the process. Comprehensive consulting services that provide a full report on the lender’s fair lending risk can take months to complete—which reduces the time that the lender has to enact changes before the CFPB, FDIC, FED or OCC issues and serves them notices.

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Many legacy tools were compliant at founding but are maintained by companies whose primary expertise is in software, not compliance. That lack of genuine understanding of complex and evolving fair lending regulation will ultimately result in functionality that does not adequately keep up with the lenders’ compliance obligations. Further, keeping all necessary staff up to date on the latest techniques can result in significant training, manual work, or additional professional services to keep up.

What are features of an ideal fair lending solution that can help lenders overcome these challenges?

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1: Implement Dynamic Redlining Analysis

Redlining has become a major concern since the CFPB announced that it would be a primary focus of their fair lending investigations. The ideal fair lending solution should make monitoring for redlining risk significantly more efficient, precise and easy to understand.

As this kind of analysis may be new to your team, find a solution developed by compliance experts, which helps automate the process so your team can spend time analyzing results rather than assembling numbers and cleansing data

2: Start with Compliance Expertise, Not Just Software Development

The ideal fair lending solution is maintained by a team steeped in regulatory compliance knowledge and who are actively participating with regulators and industry experts. This provides the best of both worlds—getting the expertise of a team with decades of experience and the speed of a dynamic fair lending solution will help you identify risks quickly so you have more time to focus on correcting potential issues.

3: Use a SaaS-Based Distribution Model

To keep as current as possible, look for Software-as-a-Service solutions, not a downloaded piece of software. This provides you with a number of key benefits, including:

Consistent & Timely Updates. HMDA and CRA peer data should be uploaded immediately following public release. New functionality can be rolled-out overnight to ensure you have the latest data and capabilities to make informed compliance decisions.

Highly Secure Infrastructure. With an ever-increasing bar for third party risk management, look for a solution, which reflects investment in higher standards for information security, control, and resilient infrastructure in which your procurement and technical teams can have confidence.

Maintenance. SaaS architecture means all the functions and software are maintained for you. This means there’s no need to download and install new patches to a local machine, saving time and money on your part. All updates are applied by the provider automatically and are live almost instantaneously.

Protection Against Data Loss. Backups of your most important compliance data are maintained so that a single server malfunction or other issue doesn’t destroy your data. This minimizes the risk of complete data loss from natural disasters, server hacks, and other events outside of a lender’s control.

4: Obtain Unrestricted Usage for Lenders

If you pay a per-seat charge for your software, you might be inclined to save money by restricting users. A solution which provides unlimited seats allows for multiple simultaneous users and collaboration. You can even engage internal and external counsel to look at findings in the same platform. This means you won’t hesitate to give access to the team member, who needs it, and no matter how many users you give access to; your subscription costs will remain the same.

Advanced Fair Lending Solutions Built by Compliance Experts

Isn’t it time that you address fair lending challenges head on by implementing the ideal fair lending solution?

Asurity Technologies began as an automated compliance product development division of Treliant Risk Advisors, a leading financial services consulting firm. It was spun out of Treliant Risk Advisors as Treliant Solutions by its investor, Temerity Capital Partners, in 2015. Following Temerity Capital Partners acquisitions of Risk Management Solutions, Inc. (RMS) and Mortgage Resources Group, LLC (MRG), Asurity Technologies was formed to combine the automated compliance solutions from Treliant Solutions, RMS, and MRG on a secure, cutting-edge technology platform. Asurity works closely with the Buckley Sandler law firm and Treliant Risk Advisors on product development and product enhancement.

About The Author

Dr. Anurag Agarwal
Dr. Anurag Agarwal serves as President of the RiskExec division with Asurity Technologies. Anurag is a recognized expert and a financial services industry veteran with over 20 years of experience in fair lending, Home Mortgage Disclosure Act (HMDA), Community Reinvestment Act (CRA), and related areas. During his career, Anurag has advised top 50 financial institutions in the areas of compliance, fair lending, statistical analysis, and regulatory risk management. Dr. Agarwal also serves as Senior Advisor to Treliant Risk Advisors.

Eliminate Risk: Three Tips For Developing Strong Risk Management Infrastructures

Improperly handling risk management efforts can make or break your loan origination process. Often, unforeseen issues arise that can be effectively dealt with, or even prevented by, the implementation of a strong risk management infrastructure.

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With potential crises just waiting to be revealed, it is beneficial for lenders to identify these risks up front, before the damage becomes irreparable. Three areas on which lenders should focus in order to protect themselves and their borrowers are title search insurance, AVM audits and the use of innovative technology for property reports.

Title Search Insurance

Performing a title search consists of locating all necessary documents to determine and verify the legal owner of a property, and additional interest(s), claims and encumbrances on the property. Having insurance on these searches protects the lender by insuring that the information presented in the search is accurate and valid. If a title search is performed without proper insurance, the lender is left responsible for any issues down the road. For example, if a lender closes a home equity loan, and two years later the borrower defaults and the lender was not aware that there was a mortgage lien filed prior to the home equity that lender is subject to any losses that could occur as a result of the error on the original property report.

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With title search insurance, any errors or missing data on the property report are covered, and the lender is guaranteed a lien position. This indemnifies the lender of fault and losses for any incorrect data on the initial report, should the borrower default on the loan. Lenders should always partner with providers that not only handle nationwide title searches for them, but also provide sufficient title search insurance.

AVM Audits

Automated Valuation Models (AVMs) allow lenders to receive information regarding a residential property at the touch of a button. They show the lender the market value for the property, the tax assessor’s indication of value, recent sales history and comparable sales analysis of similar properties. And, although some lenders lost confidence in AVMs as a result of the 2008 financial crisis, they are making a strong comeback.

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In order to keep AVMs up to date and functioning properly, lenders must perform timely audits or validation. These audits should include a thorough comparison of a sample pool with AVMs versus a benchmark, such as a standard appraisal. This allows lenders to understand the strength and accuracy of the AVM model being used and the deviations between both, enabling the lender to adjust guidelines if necessary. Auditors want to see AVM validations to ensure the AVMs are delivering accurate values on properties.

By scheduling regular audits, lenders can trust that their AVMs are presenting correct information.

Using Innovative Technology for Property Reports

Many lenders still receive property reports from third parties that manually pull information from the Internet, transpose it to a report and then deliver the package to the lender. This physical transport of data from one document to another, or the “stare and compare” approach, significantly increases the risk of human error.

Lenders should engage with providers that use technology to create property reports directly from information provided by the courthouse or credit repositories. When no data is manually input by humans, the process becomes much faster and ensures accurate information. The lender is then delivered one concise report in a timely and compliant manner.

The best way to enhance your risk management infrastructure and keep up with competitors is to partner with an expert, third-party provider that offers full title search services, including insurance, AVM audit services and technical property reports. This will not only set you apart from others maintaining out-of-date processes, but will also ensure that all parties are protected throughout the entire loan origination process.

About The Author

Tim Smith
Tim Smith is co-founder and president of Austin, Texas-based FirstClose, provider of end-to-end technology solutions to refinance and home equity lenders nationwide, as well as a vendor management system that eliminates duplicate data entry. The company’s flagship product, the FirstClose Report, is the first, comprehensive refinance and home equity loan solution with capabilities to deliver title, flood, valuation and other important data elements in one report. For more information, visit www.firstclose.com.

The Best Of Both Worlds

In today’s hyper competitive mortgage market, with fluctuating rates, an influx of regulations and enforcements, focusing on attracting new borrowers and retaining the ones you have isn’t always the top priority. It is critical to take care of those areas without losing sight of the importance on bringing on new business.

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I was reading a recent blog by IQ Total Source titled “How to Combine Print & Digital Marketing Campaigns”. In the blog they state “To be successful in today’s marketing age, it is important to have an integrated campaign: both print and digital tactics.

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Making these tools work together can be tricky, though. As with any campaign, you’ll want to start out knowing who your target audience is. This means not only knowing the demographics and parameters of your audience, but also how best to reach them. While it is easy to assume that older customers prefer print while younger customers like digital marketing, it will almost never be advantageous to operate this way.

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There are various advantages and disadvantages to both print and digital media that you should research. Most likely you’ll find that a combined print and digital marketing campaign is the way to go. Digital media is a great option because of its ease of change and the fact that you are not so strictly limited in space. You can use links to your advantage in this capacity, giving your customer an easy path of simply clicking to learn more information or even purchase your product then and there. However, print offers its own set of advantages. Information is much more easily digested in print and people like and trust something tangible.

Through both your print and digital channels, you should have a consistent look. It’s quite possible that a customer will come in contact with both your print and digital designs. Your campaign will be made stronger and clearer if your customers can easily connect the two. Make sure that the efforts you put toward your campaign can be used in as many ways as possible. Information from a newsletter can be organized in a print pamphlet or poster, used as a basis for an online banner, and expanded on for a web page. Consistency is key when managing a combined print and digital strategy.

Don’t rigidly separate your print and digital information. As we’ve already covered, it is not as black and white as assuming you’ll generate one set of customers from print and an entirely new set digitally. Including twitter handles, an invitation to visit your website, or even an online code within your print campaign can compel your audience to your digital channels and vice versa. Always make sure all of your marketing is contributing toward your desired result.

Print is not dead and digital marketing is fast growing. Both have their advantages and disadvantages, but combining them can mean the best of both worlds.”

To succeed in today’s mortgage market you need a multifaceted marketing approach to attracting, engaging and eventually bringing on new borrowers. This includes the use of both print and digital.

About The Author

Brandon Perry
Brandon Perry is President at The Turning Point. Brandon oversees all operational and administrative activities of TTP. Brandon brings over 16 years of experience in various financial services industries to TTP which enhances the Company's ability to maintain it's position as industry leader in providing customers with an advanced marketing solution.

Tradeshow Trends

Tradeshows are an important marketing tool for many businesses, but has their influence changed as companies look to promote themselves more and more online?

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Exhibition stand supplier Display Wizard surveyed 100 regular exhibitors on the pros and cons of this marketing channel and created an infographic with some of its findings.

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Tradeshows are still an important channel for many marketers, with 75% of respondents saying they saw a positive future for tradeshow marketing, and the biggest factor in whether a marketer decides to exhibit at a tradeshow is the quality of attendees, the study found.

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But many interviewees also voiced concerns about tradeshows, with the high cost of exhibiting reported as the biggest issue for most exhibitors.

Check out the infographic for more survey findings and some expert tips on how to exhibit successfully:

Progress In Lending
The Place For Thought Leaders And Visionaries

Improving Efficiencies By Combining Hazard And Investor Claims Processes

The servicer’s imperative post-foreclosure is to liquidate the property and seek recovery under whatever guaranty may exist for the loan. Given the complexity and inherent risk of these processes, servicers have traditionally engaged expert, third-party providers to assist with hazard insurance claims and investor claims. Historically, different companies have specialized in these discrete claim types, so servicers have gravitated toward the leading providers of those services to meet their specific needs.

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However, the “long tail” end of the mortgage crises has reached the areas of servicers responsible for conveyance and investor claims processing, causing volumes to spike and surfacing more comprehensive needs. So, what happens when a servicer needs assistance processing both hazard and investor claims? Must they partner with multiple providers? A few years ago, the answer might have been, “yes.” However, by bundling hazard and investor claims services, servicers can save time and money while producing better outcomes. This “collateral loss mitigation” approach recognizes the interconnectedness of processes and commonality of data elements in post-foreclosure mortgage loan servicing. By dual tracking work, compiling claims in advance, and leveraging insights gained from data processing in hazard claims, curtaiments (meeting timeframes) are minimized while recoveries for servicers are maximized.

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When a servicer engages a third-party provider for collateral loss mitigation, the investor claim begins while the hazard claim is still in process. During the resolution of the hazard claim, the third-party provider takes a proactive approach and begins work on the investor claim due to the similarities of the documents and the requests that are made when filing a hazard claim. In addition to ensuring consistency of process throughout, this approach enables the field services vendors to more quickly complete any repairs necessary to effectuate conveyance condition (“ICC”) for the property.

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We have seen a significant reduction in processing time when hazard claims adjustment and investor claims management processes are combined. In some cases, as many as ten days are shaved off the overall claims process. This streamlined approach not only reduces processing time for both types of claims, but it also potentially saves servicers hundreds of dollars per property. If a projection is done over the servicer’s portfolio, the savings could be significant with this proactive approach.

Servicers dealing with increased volumes of conveyances and investor claims should be looking to reduce risk and decrease timeframes. An effective third-party provider can assist by offering both hazard claims and investor claims processing as bundled services under the umbrella of collateral loss mitigation. This innovative approach, which combines economies of scale and commonality of data, assists in minimizing the risk of curtailments while ensuring maximum recoveries for servicers in both the hazard and investor claim domains.

About The Author

Denis Brosnan
Denis Brosnan is the president and chief executive officer of Dallas-based DIMONT, provider of specialty insurance and loan administration services for the residential and commercial financial industries in the United States. Additional information is available at www.dimont.com.

eSignatures Pay Off

PROGRESS in Lending has learned that Southern California-based First Financial Credit Union, successfully upgraded its eSignature system to IMM’s eSign plus. The business rules-based eSignature platform automates eSignature transaction processes including document signing and downstream tasks such as reviews and approvals. This enables the credit union to securely and efficiently conduct business transactions in a paperless environment while realizing significant savings across all departments.

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According to the credit union, digital banking is one of the top priorities in its yearly strategic plan. The credit union cited its long-term partnership with IMM as a critical component to meeting this goal. “Enabling electronic transactions and automating associated workflows is a key focus of our Operations area,” said Wendi Sheehy, Manager of Operations at First Financial Credit Union. “IMM was the only provider that seamlessly integrated with our Symitar Episys core platform, which was an essential requirement to ensure success. Now we are able to streamline our processes and complete them more efficiently, and by eliminating the chance for human error, we have also increased accuracy.  This gives us the freedom to focus on enhanced services that better serve our members. Our entire frontline and support staff has benefited since we implemented IMM’s eSignature platform.”

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Since implementing IMM’s eSign plus, First Financial Credit Union is able to quickly complete document transactions with fewer errors, eliminating tedious management and oversight associated with traditional paper-based processes. Credit union employees spend less time tracking down paper documents. Instead, employees concentrate on providing exceptional service to its growing membership base. This smart technology allows staff to focus more of their time on relationship development and meeting member’s needs.

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“From a member service standpoint, eSignatures are an invaluable tool,” Sheehy added. “We’ve enhanced our processes and improved the overall member experience in nearly every area of the credit union, including new account openings, stop payments, ACH disputes as well as the way we process and fund loans. Prior to implementing eSignatures, it could take up to 10 days to settle an ACH dispute. Now, it begins within minutes and the member can receive a provisional credit much faster.”

First Financial Credit Union serves the educational community with strict schedules; accessibility and convenience are a must for its members.

Sheehy continued, “IMM’s eSignature platform enables us to engage teachers and school administration at a time and place that is convenient to their schedules. This could be in between classes or after school from home. One of the greatest savings we’ve experienced is related to loan documents. Prior to eSignatures our loan documents were generated by our call center, and then were delivered via FedEx to member(s) for signatures with a return, postage paid, FedEx envelope.  This costs $32 per loan, not to mention the time delays. With remote signatures we can literally send/receive documents and fund a loan within 15 minutes as opposed to 3-5 days.”

About The Author

Tony Garritano
Tony Garritano is chairman and founder at PROGRESS in Lending Association. As a speaker Tony has worked hard to inform executives about how technology should be a tool used to further business objectives. For over 10 years he has worked as a journalist, researcher and speaker in the mortgage technology space. Starting this association was the next step for someone like Tony, who has dedicated his career to providing mortgage executives with the information needed to make informed technology decisions. He can be reached via e-mail at tony@progressinlending.com.

Capitalize On Your Content

In an article that I just read from Marissa Lyman of Marketo, she talks about “Four Things Smart Marketers Do With Press Coverage”. The same can be said about great marketing content.

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“A member of your public relations team just secured a killer placement for your company. Congratulations! This is big news—pun intended! This article has it all—corporate messaging pull-through, a nice quote from your executive, complimentary language about your organization—it’s a win all the way around. You’ve passed it around internally and everyone has replied all with comments like “very cool” and “great hit.”

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You’re done, right? That’s the extent of the value that this coverage will bring to your org.

WRONG!

If you think the press coverage is a one-and-done type of deal, think again! There are lots of things that you can do with a press hit to make it go the extra mile for your brand. You can (and should) take all that free publicity and make it work for you. Here’s how:

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Socialize It

Post that article to your social followers! Sharing stories like this over company accounts is a nice break from traditional corporate announcements and shows validation for your brand by third-party sources. Even though press coverage isn’t an endorsement, sharing articles where your company is reported on externally adds legitimacy to your narrative. That’s because studies show that earned media is considered the most trustworthy form of marketing.

And of course, if you have an executive quoted in the piece or maybe a partner or customer featured in the article, make sure all of them are tagged to give them some extra love, like greater exposure and even more follows.

Incentivize It

There are lots of tools available now to incentivize employees and brand advocates to share news like this via their social channels. Doing so allows them to spread the word to their social networks for additional reach. The benefits of using platforms like GaggleAMP or Influitive is the element of gamification, which entices employees more than an email that just says, “please share.” It’s easy to set up a rewards program (Swag! Giftcards! Money! Oh my!) through these tools, further incentivizing your coworkers for their efforts.

Put Some Paid On It

I said that to the tune of “I got five on it,” by Luniz (if you don’t know that reference, please look it up). Just because you got the hit for free doesn’t mean that you can’t give it an extra “boost.” Putting paid promotion behind the post on any social network or via a content distributor ensures that more eyeballs— especially more of the right eyeballs—will reach the article.

Much is given to a company’s website—pricing pages, product specs, customer testimonials, C-suite bios!—but I urge you to consider the page where I spend most my time: the press room. Your press room should not only include staples like your company’s most recent boilerplate and announcements (maybe even a link to your corporate blog, if you’re feeling fancy), but it should also include recent mentions of your organization in the news. It’s one thing for people to see what you’re saying about yourself when they look at this page. It’s an entirely other thing for them to see the nice things other people are saying about you”.

At the end of the day getting press coverage or creating awesome marketing content alone doesn’t ensure the results your looking for. It is critical to share the content through as many channels as possible. Looking to attract more borrowers? Maybe it is time to share more.

About The Author

Michael Hammond
Michael Hammond is chief strategy officer at PROGRESS in Lending Association and is the founder and president of NexLevel Advisors. They provide solutions in business development, strategic selling, marketing, public relations and social media. He has close to two decades of leadership, management, marketing, sales and technical product experience. Michael held prior executive positions such as CEO, CMO, VP of Business Strategy, Director of Sales and Marketing and Director of Marketing for a number of leading companies. He is also only one of about 60 individuals to earn the Certified Mortgage Technologist (CMT) designation. Michael can be contacted via e-mail at mhammond@nexleveladvisors.com.

Cybersecurity Is Really Important

The mortgage industry should pay attention to wha over industries are doing and take cybersecurity more seriously. For example, CopyStrong, a cybersecurity company focused on combating insider threats, has created an application that mitigates the risk of cyberattacks within health care organizations, the company announced Wednesday.

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Cybercrimes against health care organizations are growing exponentially more complex and frequent, especially with the increased reliance on electronic systems to coordinate care. These types of attacks increased 125 percent from 2010 to 2015, and are now considered the leading cause of data breaches according to the Ponemon Institute. The surge in cyberattacks has put pressure on hospitals to find new strategies in cybersecurity.

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“Current detection usually takes years and the costs to the organization are exorbitant. Up until now, there really hasn’t been a reliable solution to stop these bad actors and hold them accountable,” said Erica Bowles, founder of CopyStrong. “CopyStrong provides early detection from bad actors while simultaneously launching a counter intelligence protocol that minimizes victimization of patients while protecting the reputation of health care systems.”

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During a hospital visit, hundreds of people, have access to a patient’s medical records. These records can easily sell for anywhere from $300-$500 each, on the black market. Medical records are increasingly valuable because they contain personal data that can be used for further cybercrime. Unlike credit cards which can be swiftly cancelled, medical records have a long lifetime and hence a greater possibility of re-use.

“The last thing any patient wants to deal with after being hospitalized for an illness, is to then be victimized for years thereafter because of an insider theft scheme,” said Bowles. “This is happening more frequently due to inadequate or non-existent security measures surrounding the storage and use of personal medical records.”

Some people may ask, what prevents these individuals from walking out the front door with a patient’s medical records. Will purely ethics, morals and employee training manuals stop them? With cyberattacks at an all-time high these solutions appear inadequate.

In a recent article from Forbes titled “Your EHR could be worth $1,000 dollars to hackers” the author explains that the majority of all inappropriate accesses to EHR (Electronic Health Care Records) comes from the inside. They involved nurses, doctors, specialists and administrators all of whom have legitimate access to a patient’s EHR, but who have abused that access. In 2016, 450 breaches occurred, affecting 27 million patent records, and over 65 percent came from insider attacks.

In one instance, an emergency room employee at Florida Hospital used his access to collect information on patients injured in car accidents, which he then sold to chiropractors and lawyers. This went undetected from 2009 to 2011.  After he was terminated, his wife, who was also an employee at the hospital, continued the scheme. In many instances, breaches go undetected for several years.

Lenders need to pay attention to this because it applies to mortgages as well.

About The Author

Tony Garritano
Tony Garritano is chairman and founder at PROGRESS in Lending Association. As a speaker Tony has worked hard to inform executives about how technology should be a tool used to further business objectives. For over 10 years he has worked as a journalist, researcher and speaker in the mortgage technology space. Starting this association was the next step for someone like Tony, who has dedicated his career to providing mortgage executives with the information needed to make informed technology decisions. He can be reached via e-mail at tony@progressinlending.com.