SOUTH SHORE MORTGAGE

FAIR LENDING PLAN

 

 

Introduction:

 

     South Shore Mortgage has a management system that allows for an automated; streamline process of handling mortgage applications. Our marketing approach consists of a telemarketing basis.  We utilize an automated dialing system to generate interested customers.  Areas and telephone numbers are randomly selected in the states that we are licensed.  Large amounts of these numbers need to be loaded into our computer system for proper dialing.  Our system is non-biased in the fact that fifteen thousand households need to be called for effective contact. Our production is a consistent 1-1.5% return on the dialing.   This is impartial and a successful way of insuring a fair lending approach to our marketing.

 

     When an application is taken on a prospective client, the only requirement is an upfront appraisal fee.  All applications are turned in, downloaded and submitted through one of two automated systems, Fannie Mae or Freddie Mac.  This allows for a third party review solely based on underwriting guidelines from Government endorsed agencies.  Our Company has created a computer program to pre-qualify prospective applicants with the same guidelines as Fannie Mae and Freddie Mac.  This allows for a 95% success rate in application approvals. 

 

Procedures:

 

     It has been accepted and agreed that South Shore Mortgage will conduct and carry out procedures and policies in accordance with NYS Executive Law 296-a.  The following will remain in effect and implemented with our general business policies for providing an effective Fair Lending Plan.

 

1.               All mortgage applications are to be submitted in a timely manner.  No applicant will be required to submit any application fee prior to being formally underwritten. The only fee to be collected at time of application is for the appraisal.  No applicant will be denied the right to an opportunity for an approval.  All monies not utilized in the processing procedure will be refunded.

 

2.               All applications are to be submitted through Fannie Mae or Freddie Mac’s    

Automated underwriting system.  The use of a tri-merge credit report will be utilized in this evaluation to determine purchase ability for the secondary market.  South Shore Mortgage will incur the expense of obtaining the in file credit and findings from one of the agencies.  All processing and underwriting staff will strictly follow the findings outlined by the automated decision.  No underwriter is to require any additional documentation not outlined in the findings.

 

3.               In the event that the application was taken verbally, a Good Faith estimate

Along with the Truth in lending requirements of New York State will be mailed to the applicant with the Companies opening letter requirements for documentation.

     

4.               In the event an applicant is rejected, the application is immediately turned

over to the company fallout manager.  The responsibility of this manager is to discuss the client’s options and explain the problems associated with the rejection.  This manager is an employee and is not compensated or motivated by commission.  This manager will determine if the company can underwrite and place the applicant in a program that is affordable and complies with Executive Law 296-a.

   

5.               On a weekly basis all departments generate reports.  The opening

Department is required to submit to upper management a detailed report of all originations.  This report needs to be completed and presented for review.  Management will conduct quality control measures to insure proper standards are used in underwriting a file for approval.

 

6.               Files marked as rejected will be reviewed by General Management and the

The Fallout Manager.  Applications that cannot be approved are to be closed out and a rejection letter outlining the reasons for denial to be forwarded to the applicant.  A dialogue on the outcome and handling of all files are to be archived within the processing software file.

 

7.               When complaints are received on rejected files, General Management is to

Reverse the process to review the determination on the file.  The archived file is to be retrieved and reviewed by the Fallout Manager and The General Manager collectively.  A written response of the complaint will be sent to the applicant.

 

 

 

 

Conclusion:

 

     It is generally adopted that this policy will remain in effect.  The procedures will be preformed on a weekly basis to not only institute proper business practice but to insure a Fair Lending Plan.