July 14, 2015
In order to proactively determine any potential issues with HPML and high cost violations due to state requirements, REMN Wholesale is implementing the below changes effective immediately. These requirements apply ONLY to 203k loans in the states of Connecticut and New York.
- The loan MUST be locked at time of submission. If the loan comes in with a floating rate, the Account Executive and the Broker will receive an email communication from the USS informing them that the loan must be locked before it will be submitted to the Underwriting Department.
- REMN Wholesale will run all applicable compliance testing at the time of underwriting submission. The TILA Department will communicate the testing results to the Account Executive and the Broker. If there are restructuring options that need to occur, the Broker will work with their Account Executive to remedy any compliance fails.
If you have any questions, please contact your Account Executive.