IMPORTANT! The following information is only applicable to loans submitted prior to October 3, 2015. |
Compliance Alerts functionality is designed to support tests for General Compliance Alerts, Ability to Repay (ATR)/Qualified Mortgage (QM), Higher Priced Mortgage Loan (HPML), and HOEPA/High Cost Loan requirements. Users can access the Compliance Alerts before and after the loan has been finaled with the applicable user rights (noted below) by clicking Compliance Alerts in the blue Application Ribbon.
IMPORTANT! For loans with an application date after October 3, 2015, settings are available in Admin > System Admin > Channels that allow each General Alert to be enabled or disabled individually. If any of the following settings are set to “Yes”, the corresponding Compliance Alerts test will be enabled on the General Alerts tab:
TILA/RESPA Disclosure Receipt Waiting Period General Alert
TILA/RESPA 3 Day Disclosure Delivery General Alert
TILA/RESPA Redisclosure Delivery General Alert
ECOA Decision Notice Delivery General Alert
ECOA Valuation Delivery General Alert.
At the time of the release, if your current channel setting for General Alerts is set to “Yes”, then all of the above individual alerts will be set to “Yes”. At the time of the release, if your current channel setting for General Alerts is set to “No”, then all of the above individual alerts will be set to “No”.
If all of these tests are set to “No”, then the General Alerts tab will display an exempt view, displayed below, stating that the test is not configured for this institution. If an individual alert is disabled then the disabled general alert will display an exempt view stating that “Alert is not configured for this institution”.
Badges appear next to the Compliance Alerts link in the blue application ribbon and are used to indicate if the loan has passed or failed the compliance testing. A green badge with a checkmark will appear if the loan has passed all of the compliance testing that has been run at that moment. A red badge will appear if the loan has failed the compliance testing and a number appears in the red badge to identify how many of the compliance tests have failed.
Tip: The GFE and TIL screens need to be completed and saved before some of the compliance testing can be performed. See the Chapter on GFE 2010 and Itemized Fee Worksheet and the Chapter on TIL for detailed information on those screens.
The Compliance Alerts icon will not appear in the blue Application Ribbon if Compliance Alerts have not been configured in the Administrative site or if the loan application is a Pre-Approval. Users can identify a loan as Pre-Approval by marking the check box for Pre-Approval on the Borrower Summary or 1003 > Property tab. Unchecking the box for Pre-Approval will activate the compliance testing and the Compliance Alerts icon will appear in the blue Application Ribbon.
Click Compliance Alerts from the blue Application Ribbon to open the Compliance Alerts pop-up window. The Compliance Alerts window displays the compliance testing in the following five tabs:
· Overview
· General Alerts
· Ability to Repay/QM
· Higher Priced Mortgage Loan
· HOEPA/High Cost Loan
Tip: Site Administrators have the ability to configure the LOS in the Administrative site to determine the compliance testing that should be performed and only compliance testing that is enabled will display for users in the Compliance Alerts window.
Tip: A Compliance Alerts hyperlink will appear in the Loan Pipeline for loans that are failing compliance testing. Users can click on the Compliance Alerts hyperlink to open the Compliance Alerts Pop-up window and quickly view the compliance testing without going into the loan application.