MAVENT Compliance Review Training Encompass is set up to run the MAVENT Compliance Reports automatically as Milestones are “Finished”, but we encourage that a compliance report is run manually anytime numbers, loan terms or ATR/QM information changes during the loan process. The two types of MAVENT Compliance Reports are: • Order – compares current loan data to how the file was last disclosed. • Preview – reviews the current loan data. Milestone Retail Wholesale Processing Preview Preview Submittal Order Order Resub Order Order Approval Preview Preview Ready for Docs Preview Preview Doc Signing Order Order Funding Order Order The possible results that can be returned for each report are listed in order of severity below: Review Status Description Error Data is missing or entered incorrectly so the system is unable to give a determination. Action required for resolution. Fail Information entered does not meet requirements. Action required for resolutions. Alert and Warning Notifying you of a potential problems. Must investigate to determine if acceptable or not. Pass This status is delivered when the Encompass Compliance Service does not identify any exceptions with the loan data. Compliance Preview Always run the “Preview” when checking ATR/QM compliance as it reviews current loan data. “Order” will check information on how the loan was last disclosed and may not be correct for ATR/QM purposes. Compliance Preview Alerts/Warnings Alerts and Warnings need to be reviewed prior to proceeding. Some Alerts or Warnings will appear on all loans such as the HMDA Warning shown below. Remember that these are alerting/warning you of potential (not current) issues with the loans file. Fail You cannot proceed with a Fail and the issue must be resolved. Compliance Preview Fails, Warnings and Alerts If a Fail, Warning or Alert is received, the body of the report will identify the issue. Verifies if loan is compliant with all ATR/QM requirements. Verifies the TILA tolerance and that the disclosed finance charge and APR are within tolerances defined by TILA. Verifies if loan is considered a High Cost loan. We should never have a High Cost loan as SNMC does not do High Cost loans. Verifies if loan is an HPML. If loan is HPML & conventional, VA or USDA, the residual income worksheet is required. Verifies if loan meets all state requirements and laws. Verifies all involved parties meet license requirements including the lender is licensed in the particular jurisdiction, licenses are active & in good standing, license authorizes the lender to originate the type of transaction. Verifies the individual loan originator’s NMLS information against NMLS data bases. This reviews the allowable points and fees thresholds as defined by the appropriate agency. Enforces specific requirements depending on loan type. Reviews the pertinent loan data to HMDA requirements Compares all the loan’s borrowers names and aliases against several government lists including the OFAC list and the SSN death master files. This checks for anything that doesn’t fall in the other categories such as: Preview Mapper, Service Info, etc.
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