MReport May 2017

TheMReport — News and strategies for the evolving mortgage marketplace.

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TH E M R EP O RT | 23 © 2016 Fair Isaac Corporation. All rights reserved. Is your migration plan ready? Learn more about FICO ® Score 9, the most current and predictive FICO ® Score. under the new TRID rules, and when those disclosures are issued. It will also be used to determine the loan approval and the value of the underlying col - lateral. Finally, such information will be the basis to populate the final property, product, and consumer information in the final legal and closing documents. As you can clearly see, it is imperative that the LOS data be absolutely accurate in every detail. Otherwise the loan is built on a very shaky foundation. Be Careful, Clear, and Honest. T o help avoid UDAAP violations, lenders need to understand the rules, train their employees, monitor all advertising and consumer communica - tions, and ensure the integrity of the information used for the loan in their LOS. Web advertising and advertising done via social media carry the same legal requirements as those done in print media, on the radio, or on TV. There are no exceptions. They all must be crystal clear regarding what is being presented, under what specific terms, for what period of time, including any special conditions or considerations, and spell out what the consumer may expect in return. This isn't rocket science; it's just good old-fashioned, honest advertising; cus - tomer service; and data integrity. Know what you originate; advertise what you sell; and deliver what you advertise. That will go a long way in helping to avoid any UDAP and/or UDAAP en - forcement actions, as well as other loan defects that will get you into trouble. Stay compliant, my friends. MICHAEL L . VITALI, SR. presently serves as SVP/Chief Compliance Officer of LoanLogics, monitoring regulatory developments and their practical implications for lenders, servicers, and vendors in order to support executive management in high-level strategic decision-making. This includes identifying new market opportunities and new product enhancements. He supports the company's compliance analysts on a day-to-day basis, including reviewing and approving the scope and substance of compliance reviews, answering loan-level questions, and participat - ing in the preparation for, and defense of, client regulatory exams.

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