20 hrsafe prelicensing2013slidesstudentversion

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for the students of Jillayne Schlicke's loan originator pre-licensing class.

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20 hrsafe prelicensing2013slidesstudentversion

  1. 1. 20 Hour SAFE Comprehensive Pre-Licensing and Exam Prep Jillayne Schlicke
  2. 2. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 1 Introduction  Introduction of trainer  Introduction of students  Review the course syllabus 2
  3. 3. National Association of Mortgage Fiduciaries Jillayne Schlicke Intros  Name, where you work  Do you work in lending? How long?  Exam Anxieties 3
  4. 4. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 1 Module 1.1 UST Uniform State Test $110 3 hrs, 10 min 115 questions plus 10 sample questions 75% to pass If you pass you will know your score. If you fail, they will give you a printout showing your strong and weak areas. Prometric.com 4
  5. 5. National Association of Mortgage Fiduciaries Jillayne Schlicke Exam Components 25% Federal Law RESPA, TILA, ECOA, FCRA, SAFE 20% General Mortgage Knowledge programs, products, terms 20% Loan Origination application, qualifying, title, escrow, math 15% Ethics consumer protection, fraud, fair housing 20% Uniform State Content licensing law, prohibited practices 5
  6. 6. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 1 Module 1.1 Exam prep basics: If you understand the purpose of each law, you are on your way to selecting the best answer on a multiple choice exam. There will be two obvious wrong answers. If you know the purpose of the law, you will be able to spot these. Of the two that remain, one will be a little bit better than the other. Exam writers do not write trick questions. The language of the test questions look tricky because you are being tested on law and most lay people are not use to reading law on a daily basis. This is the only fair way to deliver a 50-state exam. 6
  7. 7. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 1 Module 1.1 There are many different learning styles. I will try to touch all of these throughout the next two days. Auditory-learns by listening Visual-learns by processing images Tactile-learns best when writing Whole Body-learns best when entire body is engaged Emotional-learns best when complex info can be tied to an emotion Learning disabilitiesYou may be eligible for extra accommodations if you have a diagnosed learning disability. Contact the NMLS after reading the exam candidate handbook. 7
  8. 8. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 2 Module 2.0 Depository Bank Checking, savings CAN fund its own loans LOs are “registered” Mortgage Broker No ck/svgs Does NOT fund its own loans Pure middleman For a fee, finds the mortgage money LOs are licensed. In some states, these LOs owe fiduciary duties to clients Non-Depository Lender Non-Bank Lender No ck/svgs CAN fund its own loans via lines of credit with banks LOs are licensed 8
  9. 9. National Association of Mortgage Fiduciaries Section 2 Module 2.1 There are many moving parts in the Mortgage Machine. The function of loan origination is just one piece. Jillayne Schlicke Title Insurance, Escrow Secondary market Underwriting Appraiser Home inspector Loan originator LO Assistants Loan processors Realtors/ Real estate brokers Mortgage insurance Hazard insurance Flood insurance State/Fed regulators 9
  10. 10. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 2 Module 2.2 Residential Loan Application Assignment: Break into small groups and talk about sections of the loan app:  What sections might the customers ask you about?  What sections might the customer consider lying?  What sections might the customer refuse to provide information? 10
  11. 11. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 2 Module 2.2 Large group discussion: Occupancy Assets HMDA Education DOB Former employer Ways of holding title Acknowledgement, signature 11
  12. 12. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 2 Module 2.3 Last two most recent paystubs Last two years W-2s Last three months bank statements Most recent statement on 401Ks or IRAs Documentation of ownership of stocks, bonds Last two months statements from any investment account Information on current mortgage or landlord contact info Soc number or green card for all borrowers or co-signers Letter of explanation for any known credit problems Documentation supporting any other income For self employed, borrowers paid on commission or in the field of sales, and borrowers who own other real property: Two years signed personal tax returns IRS FORM 4506-T 12
  13. 13. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 2 Module 2.4 FIRST RATIO PITI Principal, Interest, Taxes, Insurance Divided by Total gross monthly income =% SECOND RATIO PITI plus all other monthly revolving debt Divided by Total gross monthly income =% 13
  14. 14. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 2 Module 2.5  Loan Processing  As documents are received, processors compare the information verified to the original loan application and consult the credit underwriting guidelines.  A processor is a liaison between the originator, the borrower, the Realtor, underwriting and management. 14
  15. 15. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 2 Module 2.6  Underwriting  Sufficient and stable monthly income  Prior credit history  Assess collateral  Sufficient down payment Other factors: Payment shock, debt-to-income ratios, cash on hand after closing, other compensating factors 15
  16. 16. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 2 Module 2.7  Case Study: David and Ryan  Read the case study. Break into small groups and discuss: Is this an approvable loan?  Large group recam 16
  17. 17. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 2 Module 2.8  Ability to Repay Rule under Dodd Frank Act 1. 2. 3. 4. 5. 6. 7. 8. Eight factors: Current income and assets Current employment Monthly mortgage payment Monthly payment on simultaneous loans Property taxes, fire/flood insurance, HOA dues Debts including alimony or child support Monthly total DTI ratio Credit history Underwriters CAN consider other factors 17
  18. 18. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 3 Credit Module 3.1 Assignment: Break into small groups. Read the credit report. Question: Does this person posses decent and reasonable credit history? If yes, why? If no, why not? 18
  19. 19. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 3 Module 3.2 What’s in a FICO Score? 19
  20. 20. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 4 Title Insurance Module 4.1 What does it mean when we say we hold title to something? Is there a document called “title” that we get when we buy a home? Can we do anything we want with and to our home and land? How deep into the ground and how high up do our property rights extend? 20
  21. 21. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 4 Title Insurance Module 4.2 For a one time fee, a title insurance company will check the public records system and disclose all matters that affect the title of real property. They will insure against loss and defend you should somebody lay claim to your title. Pay once, it’s good for as long as you or your heirs own the property. Starts the day of closing and looks backward in time. 21
  22. 22. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 4 Title Insurance Module 4.3 How does a title company protect residential homeowners and residential lenders? 22
  23. 23. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 4 Module 4.4 Case Study Small group assignment: Read the case study “John and Sara” Come up with 10 things a loan originator must discuss/discover before moving forward with this transaction. 10 documents 10 questions… 23
  24. 24. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 4 Module 4.5 Legal rights and responsibilities of a title company. 24
  25. 25. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 5 Module 5.1 What is escrow? 25
  26. 26. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 5 Escrow Module Module Module Module Module Module 5.1 5.2 5.3 5.4 5.5 5.6 26
  27. 27. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 6 Appraisals Module Module Module Module Module 6.1 6.2 6.3 6.4 6.5 27
  28. 28. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 7 Mortgage Math Module 7.0 Module 7.1 Module 7.2 Assignment: Complete the mortgage math calculations together as a group. 28
  29. 29. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8  Mortgage Loan Programs:  Conforming Conventional Loans  Fannie Mae, Freddie Mac  Government Loans  FHA, VA, USDA 29
  30. 30. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8  Module 8.1  Conventional, Conforming Loans  Conforming to guidelines established by Fannie Mae and Freddie Mac. This means loans can be packaged and sold to Fannie or Freddie on the secondary market.  Handout: Fannie Mae Eligibility Matrix 30
  31. 31. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 FHA FHA = Federal Housing Administration FHA provides mortgage insurance on low down payment loans made by FHA-approved lenders U.S. Department of Housing and Urban Development was created through the US Housing Act of 1937. HUD does lots of things: 31
  32. 32. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 FHA What does HUD do? Provides opportunities for homeownership Provides housing assistance for low income persons Helps to rehabilitate and maintain affordable housing Enforces Fair Housing laws Helps the homeless Spurs economic growth in distressed neighborhoods
  33. 33. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 Insuring and Endorsement When an FHA loan closes, the lender collects and remits an up front MIP directly to HUD via wire transfer. Then the lender sends the original loan file (aka case binder) to the FHA HOC for review. If the paperwork is in order, HUD transmits an electronic MIC (mortgage insurance certificate.)
  34. 34. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 GNMA = Government National Mortgage Association Ginnie Mae is not a lender nor does it buy or sell mortgages. GNMA guarantees Residential Mortgage Backed Securities that are backed by pools of FHA loans GNMAs are backed by the federal government
  35. 35. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 Only an FHA-approved lender can originate FHA loans Property Types: 1 to 4 unit properties Purchases up to 96.5% LTV Borrower Contributions 3.5% cash investment 100% gift acceptable
  36. 36. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 Reserves are not required on 1 & 2 unit properties FHA loans are fully assumable No income limitations FHA Loans are only to owner occupied borrowers Exceptions: HUD owned property Non-owner occupied purchase at 85% LTV
  37. 37. National Association of Mortgage Fiduciaries Section 8 Module 8.2 FHA Home Mortgage Insurance Programs: 203b Single Family 234c Condo 203h Disaster Victims 255 HECM 203k Rehab EEM Energy Efficient Mortgage Jillayne Schlicke
  38. 38. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 Single Family Owner occupied 1 to 4 units PUDs (Planned Unit Developments) Manufactured Homes The FHA Mortgage Insurance Fund is running out of money…. $3.5 billion left after transferring $9.8 billion to cover possible losses on its loan portfolio. This means higher mortgage insurance premiums
  39. 39. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 Roles Loan originator satisfies the processor Processor satisfies the underwriter Underwriter satisfies management Management satisfies FHA Role of the underwriter is to build a defensible position FHA satisfies minimum risk for FHA Lenders set minimum risk for themselves FHA might say yes but your lender might say no.
  40. 40. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 Social Security Number Handbook 4155.1 paragraph 3-1C HUD/FHA require all lenders to ensure that each FHA borrower, co-borrower and co-signer has their own valid Social Security Number as issued by the Social Security Administration Verification also through FHA Connection
  41. 41. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 U.S. Citizenship Not Required FHA will insure mortgages made to lawful permanent and non-permanent resident aliens Permanent resident alien: Must have evidence of permanent resident status Have a valid social security number Non-permanent resident alien Property must be their principal residence Must be eligible to work in the U.S. Have a valid social security number Have likelihood of continued lawful status
  42. 42. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 Documentation acceptable to verify social security number includes: Paystub Valid tax return Copy of SSN card Driver’s license Medical information Service provider with access to SSA
  43. 43. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 FHA Underwriting TOTAL Scorecard Factors: Credit FICO score Monthly housing expense ratio Number of monthly payments in reserve Loan to value ratio Loan term These are the five biggest risk factors and the only things TOTAL looks at. Accept or Refer
  44. 44. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 FHA Underwriting: What must an FHA borrower possess? Decent and reasonable credit history Perfect credit is not a requirement. Stable, reliable, and sufficient income Verified funds to close Sufficient security for the loan
  45. 45. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.2 The Four Cs of Underwriting: Character Credit Capacity Income Collateral Value Capital Liquid assets • Does the borrower have the ability and willingness to repay the loan?
  46. 46. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 8 Module 8.3 VA = Veteran’s Administration See course book Section 8 Module 8.4 USDA = U.S. Department of Agriculture. Rural Loans See course book 46
  47. 47. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 9 Assignment Review the CSBS/AAMR Guidance on Non-Traditional Lending CSBS = Conference of State Bank Supervisors AAMR = American Association of Mortgage Regulators Oct 2006 banking regulators published guidelines on non-trad lending. Examples: Interest only loans Pay option ARMs Reduced/no documentation Simultaneous second lien 47
  48. 48. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 9 CSBS/AAMR Guidance  Ability to repay  Watch for payment shock  Assure borrower understands the loan terms  Avoid misleading claims…payment, rates, refi-out  Risk management strategies 48
  49. 49. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 9 Non-Traditional Lending Module Module Module Module Module Module Module Module Module Module Module 9.1 9.2 Non Conforming Jumbo 9.3 Alt A 9.4 Hard Money and Private Money 9.5 ARMs 9.6 ARM features 9.7 ARM Caps 9.8 Hybrid ARMs 9.9 Option ARMs 9.10 HECM Reverse Mortgage Loans 9.11 Suitability 49
  50. 50. 20 Hour SAFE Comprehensive Pre-Licensing and Exam Prep Jillayne Schlicke DAY 2
  51. 51. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Ethics Module Module Module Module Module 10.1 10.2 10.3 10.4 10.5 Use the following: course book Section 10 Ethics handout 51
  52. 52. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.1 Ethics Law Minimum moral standard “Have to” Ethics When there’s no clear statement in the law telling us what to do. “Ought, should.” 52
  53. 53. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.2 Ethics Different sources of moral authority Religion We can’t use religion to solve ethical dilemmas when holding a professional role because there are thousands of different religions in the world. Which one would we us? Intuition Intuition can sometimes steer us in the wrong direction Emotion “If I can’t sleep at night it’s not ethical.” If the only reason we’re choosing to do/not do something is out of fear, that’s a pretty low standard of motivation 53
  54. 54. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.2 Ethics Different sources of moral authority Written codes of ethics There is no source of moral authority over LOs other than the law. What written codes of ethics that do exist are voluntary and not mandatory. The written codes of ethics that exist are weak, vague, have no sanctions for violations and in most cases, just simply restate federal law. Philosophical ethics Moral philosophical ethical theories can take the place of a mandatory code of ethics until one is written. 54
  55. 55. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.3 Professional Status Specialized knowledge Formal, pre-licensing education Mandatory continuing education Test Licensing Fiduciary Duties Code of ethics with sanctions for violations Compare to non-professionals such as a retail salesperson. 55
  56. 56. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.3 and 10.5 Question: Are loan originators professional? Specialized knowledge Formal, pre-licensing education Mandatory continuing education Test Licensing Fiduciary Duties (this is emerging in some states) Code of ethics with sanctions for violations (this piece is not yet in place.) LOs are classified as “an emerging profession.” 56
  57. 57. National Association of Mortgage Fiduciaries Aristotle Respect honesty (promotes autonomy) Loyalty Responsibility Integrity Beneficence Non-maleficence Compassion Justice 384 BC-322 BC Kant Duty-based ethics If we have a duty to do something, we ought do it. What I want for myself, I must also want for the other. 1724-1804 Jillayne Schlicke J.S. Mill Utilitarianism Maximize good consequences for the most number of people and also minimize bad consequences for the most number of people 1806-1873 57
  58. 58. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.4 Assignment: Small group discussion: What do you remember from past classes in ethics? What is ethics? Think about a person you admire or look up to as a mentor, living or dead. What do admire about that person? Think about an ethical dilemma you’ve faced in your career. How did you solve your dilemma? 58
  59. 59. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.4 Assignment: Large group recap after small group discussion, while instructor slowly completes the slide with the three normative moral theories. Lacking any mandatory, prescriptive and descriptive ethical code, this is the best way for LOs to learn ethics. The next slide lays out the following: --what kind of person do I want to become? --what duties do I have? --what are the possible consequences? 59
  60. 60. National Association of Mortgage Fiduciaries Aristotle Respect honesty (promotes autonomy) Loyalty Responsibility Integrity Beneficence Non-maleficence Compassion Justice 384 BC-322 BC Kant Duty-based ethics If we have a duty to do something, we ought do it. What I want for myself, I must also want for the other. 1724-1804 Jillayne Schlicke J.S. Mill Utilitarianism Maximize good consequences for the most number of people and also minimize bad consequences for the most number of people 1806-1873 60
  61. 61. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.4 Moral Development 22+ 16 to 22 12 to 16 6 to 12 3 to 5 0 to 2 The intrinsic worth, value and dignity of all human persons. Some laws might not be moral Law , society’s rules The good, norms, roles, shared values Practical agreements Morality comes from external sources 61
  62. 62. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.5 Fiduciary Duties Come from Agency Law Agency: Consent by one person (principal) that the other (agent) act on his or her behalf. Agency can be created by oral or written agreement OR it may be implied through conduct. “I can get you the best loan” “I can get you the best rate” 62
  63. 63. National Association of Mortgage Fiduciaries Coercion Jillayne Schlicke Manipulation Persuasion Completely Non-Controlled Influences Completely Controlled Influences Substantially Controlling Substantially Not Controlling Section 10 Module 10.5 63
  64. 64. National Association of Mortgage Fiduciaries Duty of Loyalty Duty of Care Jillayne Schlicke What Fiduciary does will, in good faith, advance the interests of the client and not the Fiduciary’s personal interests Act in good faith Reasonable person test Informed Section 10 Module 10.5 64
  65. 65. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.5 Fiduciary Duties May Include… 1. Disclose all loan information to the borrower 2. Act in good faith and deal fairly 3. Avoiding secret fees or undisclosed fee splitting 4. No self dealing 65
  66. 66. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 10 Module 10.5 Fiduciary Duties are Higher When… Broker/LO has higher level of knowledge, experience, skills Client has limited knowledge Client is relying exclusively on you Greater the imbalance the higher the duty 66
  67. 67. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 11 Fair Housing Module Module Module Module Module Module Module 11.1 11.2 11.3 11.4 11.5 11.6 11.7 67
  68. 68. National Association of Mortgage Fiduciaries Section 11 Module 11.1, 11.3 Realtors and lenders have great power to affect neighborhoods Intent v. Effect Jillayne Schlicke 1968 Civil Rights Act 1968 Fair Housing Act ~ Protected Classes: Race Color Religion (Creed) Sex National Origin Familial Status Sexual orientation added in 2012 Disability Fair Housing/Fair Lending http://www.hud.gov/offices/fheo/lending/index.cfm 68
  69. 69. National Association of Mortgage Fiduciaries Section 11 Module 11.2  Redlining Denying or increasing the cost of services to residents of a racially specific geographical area Jillayne Schlicke  Blockbusting  Steering Guiding prospective homebuyers to or away from a specific neighborhood based on his/her race Fair Housing/Fair Lending http://www.hud.gov/offices/fheo/lending/index.cfm Encouraging white property owners to sell their homes at a loss by fraudulently implying that racial or religious minorities were moving into their neighborhood 69
  70. 70. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 11 Module 11.4 In Mortgage Lending: No one may take any of the following actions based on race, color, national origin, religion, sex, familial status or handicap (disability): Refuse to make a mortgage loan Refuse to provide information regarding loans Impose different terms or conditions on a loan, such as different interest rates, points, or fees Discriminate in appraising property Refuse to purchase a loan or Set different terms or conditions for purchasing a loan. Fair Housing/Fair Lending http://www.hud.gov/offices/fheo/lending/index.cfm 70
  71. 71. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 11 Module 11.7 Fair Housing Thought Questions Should sexual orientation be added as one of the protected classes? Should we make a woman on maternity leave return to work before counting her income when qualifying for a loan? Should we make long term disabled applicants provide additional documentation proving that they will stay disabled? Fair Housing/Fair Lending http://www.hud.gov/offices/fheo/lending/index.cfm 71
  72. 72. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 12 Consumer Protection Module 12.1 Module 12.2 Module 12.3 Case Study: Carnell v. KMC Funding Read the case. In small groups discuss the questions. As a large group, share your answers 72
  73. 73. National FBI US Department of Justice Association of Mortgage the Public 2010-2011 Financial Crimes Report to Fiduciaries Jillayne http://www.fbi.gov/stats-services/publications/financial-crimes-report-2010-2011 Schlicke Section 13 Mortgage Fraud Module Module Module Module Module 13.1 13.2 13.3 13.4 13.5 FBI US Department of Justice Financial Crimes Report to the Public 2010-2011 http://www.fbi.gov/stats-services/publications/financial-crimes-report-2010-2011 73
  74. 74. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 13 Module 13.1 Fraud for Housing, or fraud for property, is perpetrated by borrowers and/or one or more industry professionals when they misrepresent information on the loan application. This type of fraud does not usually result in significant losses to a financial institution. . FBI US Department of Justice Financial Crimes Report to the Public 2010-2011 http://www.fbi.gov/stats-services/publications/financial-crimes-report-2010-2011 74
  75. 75. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 13 Module 13.1 Fraud for profit consists of systematic transactions by industry professionals who are attempting to steal a significant amount of the funds associated with one or more mortgage transactions. This type of fraud usually involves multiple parties in various disciplines within the mortgage industry, such as mortgage originators, appraisers, real estate brokers, escrow closers, builders and title companies. Fraud for profit usually results in significant—if not catastrophic—losses to financial entities involved in mortgage loan transactions and it is of major concern to the mortgage industry FBI US Department of Justice Financial Crimes Report to the Public 2010-2011 http://www.fbi.gov/stats-services/publications/financial-crimes-report-2010-2011 75
  76. 76. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 13 Module 13.2 Property Flipping Silent Second Straw Borrowers Identity Theft Appraisal Fraud Foreclosure Rescue Equity Skimming Loan Mod Scams Short Sale Fraud FBI US Department of Justice Financial Crimes Report to the Public 2010-2011 http://www.fbi.gov/stats-services/publications/financial-crimes-report-2010-2011 76
  77. 77. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 13 Module 13.3 Red Flags When seeking employment as an LO When working with real estate agents or Realtors When working with consumers FBI US Department of Justice Financial Crimes Report to the Public 2010-2011 http://www.fbi.gov/stats-services/publications/financial-crimes-report-2010-2011 77
  78. 78. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 13 Modules 13.6-13.20 SARS Suspicious Activity Reports AML Anti Money Laundering Financial Crimes Enforcement Network Anti-Money Laundering Program and Suspicious Activity Report Filing Requirements for Residential Mortgage Lenders and Originators AGENCY: Financial Crimes Enforcement Network (‘‘FinCEN’’), Treasury. ACTION: Final rule. Federal Register / Vol. 77, No. 30 / Tuesday, February 14, 2012 / Rules and Regulations Page 8159 Subpart C—Reports Required To Be Made by Loan or Finance Companies http://www.gpo.gov/fdsys/pkg/FR-2012-02-14/pdf/2012-3074.pdf 78
  79. 79. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 14 Reflect on everything learned today. …any final questions? Preview of tomorrow. 79
  80. 80. 20 Hour SAFE Comprehensive Pre-Licensing and Exam Prep Jillayne Schlicke DAY 3
  81. 81. National Association of Mortgage Fiduciaries The Main Fed Law Acronyms TILA Truth in Lending Act MDIA Mortgage Disclosure Improvement Act RESPA Real Estate Settlement And Procedures Act ECOA Equal Credit Opportunity Act FCRA Fair Credit Reporting Act SAFE Secure and Fair Enforcement Act Jillayne Schlicke 81
  82. 82. National Association of Mortgage Fiduciaries Jillayne Schlicke CFPB = Consumer Financial Protection Bureau All federal laws governing mortgage lending are now regulated by the CFPB with one exception: Fair Housing stays with HUD Each state also regulates it’s own state laws governing mortgage lending 82
  83. 83. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 Truth in Lending Act Modules 16.1-16.3 Purpose: To promote informed use of credit. (Instead, creates mass confusion.) Gives consumers the right to cancel some transactions (owner occupied refi), regulates variable rate loans TILA Disclosures: 3 days from date of application, final disclosure at settlement Disclosure content: variable rate features, payment schedule, demand feature, prepayment penalty, security interest in the property, insurance cancellation, assumption policy, contract loan number CHARM Booklet required on ARM loans Truth in Lending Act http://www.fdic.gov/regulations/laws/rules/6500-200.html 83
  84. 84. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 Truth in Lending Act Modules 16.3 Four Government Boxes This info must be presented in clear and conspicuous place: Annual Percentage Rate/APR (the cost of the loan expressed in the form of a rate) Finance Charge Interest + closing costs Amount Financed Loan amount less closing costs Total of Payment All P&I if all payments made Truth in Lending Act http://www.fdic.gov/regulations/laws/rules/6500-200.html 84
  85. 85. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 Truth in Lending Act Modules 16.4 Rescission: on an o.o. refinance, the borrower has 3 days after signing the final loan documents to cancel and receive a full refund from the lender. LOs must refund any money collected for third party services, even if spent. For TILA RESCISSION purposes, business days include Saturday. Can the 3 day right of rescission ever be waived? Truth in Lending Act http://www.fdic.gov/regulations/laws/rules/6500-200.html 85
  86. 86. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 TILA Module 16.4 Case Study: What is the first business day on which funds may be disbursed if: Signing date: Thurs, May 2   1st bus. day: Fri, May 3 2nd bus. day: Sat, May 4 Sun, May 5 3rd bus. day: Mon, May 6 The loan can fund on Tuesday May 7th Truth in Lending Act http://www.fdic.gov/regulations/laws/rules/6500-200.html 86
  87. 87. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 TILA Module 16.4  How many copies of the rescission notice?  3  1---stays in the escrow closer’s file  2 are mailed to the borrower  If the borrower rescinds, one is signed and mailed to escrow, and the other the borrower keeps 87
  88. 88. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 Truth in Lending Act A closer look at APR (Annual Percentage Rate) APR is a measure of the cost of credit, expressed as a nominal yearly rate. It relates the amount and timing of value received by the consumer to the amount and timing of payments made. Disclosure of the APR is central to the uniform credit cost disclosure envisioned by the TILA. Truth in Lending Act http://www.fdic.gov/regulations/laws/rules/6500-200.html 88
  89. 89. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 Truth in Lending Act A closer look at APR (Annual Percentage Rate) Common consumer question: What costs are included when calculating APR? At a typical mortgage company, software systems are already programmed to do this for LOs. However, customers ask questions about the TILA disclosure forms and regulators expect licensees to know how to answer basic questions about the information contained in the TILA disclosure form. Truth in Lending Act http://www.fdic.gov/regulations/laws/rules/6500-200.html 89
  90. 90. National Association of Mortgage Fiduciaries Included Prepaid interest Mortgage insurance premiums Wire transfer fees Recording fees Loan origination fee Mortgage broker fee Escrow (closing fee) Discount points Pest inspection (VA only when prop is located in mod to high probability of area of pest infestation and lender is paying for it. Flood Ins. premiums Jillayne Schlicke Excluded Hazard Insurance (IF obtained from a neutral company) Seller paid points Document prep fee Title insurance (lender policy) Notary fee Appraisal Credit report Impounds for taxes & ins Flood Hazard Check http://www.fdic.gov/regulations/laws/rules/6500-200.html 90
  91. 91. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 Truth in Lending Act A closer look at APR (Annual Percentage Rate) Tip: How to remember which costs are included/excluded when calculating APR: Costs included These are costs that benefit the lender or costs that the lender requires in order to obtain a loan. Costs excluded These are costs that are paid to and benefit third parties other than the lender. Truth in Lending Act http://www.fdic.gov/regulations/laws/rules/6500-200.html 91
  92. 92. National Association of Mortgage Fiduciaries Jillayne Schlicke APR Tolerances…Can we make a mistake and still be in compliance? Yes:  Example: |________|_______ APR 7.75_______|________| .25 .125 .125 .25 ARM FRM FRM ARM ARM = Adjustable Rate Mortgage FRM = Truth in Lending ActMortgage Fixed Rate http://www.fdic.gov/regulations/laws/rules/6500-200.html 92
  93. 93. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 a closer look at APR  Prepaids  Prepaid finance charges = CLOSING COSTS  Impounds = a few months payments of real estate taxes, hazard insurance 93
  94. 94. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 What items are included when calculating APR? Closing Costs (prepaid finance charges) Loan term Note rate Loan Amount 94
  95. 95. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 What is the APR for the following loan? Closing costs: $2,000 Loan term: 360 months Note rate: 5.0% Loan amount: $200,000 a) 5.0 b) 4.9 c) 5.08 d) 6.98 95
  96. 96. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 Module 16.5 HOEPA = Home Ownership and Equity Protection Act A loan is covered by HOEPA if it meets the following tests: *On a first mortgage, the APR exceeds by more than eight points of Treasury maturity rates. *For a second mortgage, the APR exceeds by more than ten points the rates of on Treasury maturity rates. *Total fees and points payable by the consumer at or before closing exceed the larger of $583 or eight percent of the total loan amount. 96
  97. 97. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 16 Module 16.6 Truth In Lending Act Quiz 97
  98. 98. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 17 Mortgage Disclosure Improvement Act MDIA Module Module Module Module Module Module 17.1 17.2 17.3 17.4 17.5 17.6 --take the TILA/MDIA Quiz Truth in Lending Amendments Regulation Z, Subpart C, Closed End Credit, Section 226.17, General Disclosure Requirements Effective July 30, 2009 98
  99. 99. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 17 MDIA Module 17.3 We now have three categories of mortgage loans HOEPA (Added in 1994 as Section 32 of TILA) High cost/2nd mtg/HELOC Higher Priced (Added in 2009 as part of MDIA) 1.5 or more points higher (APR) FRM 3.5 or more points higher for a subordinate lien QRM Qualified Residential Mortgage (Added as part of the Dodd Frank Act of 2010) Truth in Lending Amendments Regulation Z, Subpart C, Closed End Credit, Section 226.17, General Disclosure Requirements Effective July 30, 2009 99
  100. 100. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 17 Module 17.6 MDIA Quiz 100
  101. 101. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 17 Module 17.6 Quiz Review TILA Quiz Question 6 Mon Tues Wed Thurs July July July July 9 Consumer must receive disclosures 10 11 12 Signing is scheduled 101
  102. 102. National Federal Reserve AssociationRegulation Z: Loan Originator Compensation and Steering 12 CFR 226 of Mortgage Fiduciaries http://edocket.access.gpo.gov/2010/pdf/2010-22161.pdf Jillayne Schlicke Section 18 Federal Reserve Board (FRB) rule on Loan Originator Compensation Module 18.1 Background FTC v. Golden Empire Mortgage Federal Reserve Regulation Z: Loan Originator Compensation and Steering 12 CFR 226 http://edocket.access.gpo.gov/2010/pdf/2010-22161.pdf 102
  103. 103. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 18 Federal Reserve Board Rule on Loan Originator Compensation Module 18.2 Three main prohibitions: P1: Compensation based on a transaction’s term or conditions. P2: Compensation by someone other than the consumer. P3: Prohibitions against steering. Federal Reserve Regulation Z: Loan Originator Compensation and Steering 12 CFR 226 http://edocket.access.gpo.gov/2010/pdf/2010-22161.pdf 103
  104. 104. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 18 Federal Reserve Board Rule on Loan Originator Compensation Module 18.2 Three main prohibitions: P1: Compensation based on a transaction’s term or conditions: > Payment based on transaction terms or conditions. > Compensation cannot go up or down based on the loan’s terms or conditions. > Minimum or max dollar amount of compensation may not vary with each loan. Federal Reserve Regulation Z: Loan Originator Compensation and Steering 12 CFR 226 http://edocket.access.gpo.gov/2010/pdf/2010-22161.pdf 104
  105. 105. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 18 Federal Reserve Board Rule on Loan Originator Compensation Module 18.2 Three main prohibitions: P2: Compensation by someone other than the consumer. If an LO will be compensated by the consumer, the LO may not also receive compensation from the lender funding the loan, or any other person connected with that transaction. Federal Reserve Regulation Z: Loan Originator Compensation and Steering 12 CFR 226 http://edocket.access.gpo.gov/2010/pdf/2010-22161.pdf 105
  106. 106. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 18 Federal Reserve Board Rule on Loan Originator Compensation Module 18.2 Three main prohibitions: P3: Prohibitions against steering. LOs may not steer a consumer to a loan only because the LO will be compensated at a higher rate by selling that product, unless the loan is in the best interest of the consumer. Federal Reserve Regulation Z: Loan Originator Compensation and Steering 12 CFR 226 http://edocket.access.gpo.gov/2010/pdf/2010-22161.pdf 106
  107. 107. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 18 Federal Reserve Board Rule on Loan Originator Compensation Module 18.3 Review the Section 18 Handout: RESPA Roundup RESPA Roundup: Compliance Guide for REPA as it applies to the Federal Reserve Board’s MLO Compensation Rules Published on Sept 24, 2010 107
  108. 108. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 19 Real Estate Settlement and Procedures Act RESPA Modules 19.1-19.2 Applies to all federally related loans; sale or refi, primary market loans only. Exemptions: 25 acres or more, temporary financing, assumptions with lender approval, conversions (contract to deed), secondary market transactions, vacant property. Which entities must comply? Real Estate Settlement and Procedures Act http://www.hud.gov/offices/hsg/ramh/res/respa_hm.cfm 108
  109. 109. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 19 RESPA Modules 19.1-19.2 Which entities must comply? Lenders (banks, brokers, etc.) Real estate agents/Realtors Title and XO Appraisers Home inspectors Mortgage insurance companies Credit reporting agencies Flood hazard check companies Attorneys Hazard insurance companies Home warranty companies Builders Real Estate Settlement and Procedures Act http://www.hud.gov/offices/hsg/ramh/res/respa_hm.cfm 109
  110. 110. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 19 RESPA Modules 19.1-19.2 Purpose Timely disclosure of settlement costs Limits on escrow reserve accounts Prohibits seller-directed title insurance Forbids kickbacks (Section 8. See next slide) GFE and HUD 1 Disclosure of Affiliated Business Arrangements Disclosure of potential loan servicing charges “Settlement Cost Booklet” Lender required use agreements Real Estate Settlement and Procedures Act http://www.hud.gov/offices/hsg/ramh/res/respa_hm.cfm 110
  111. 111. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 19 RESPA Modules 19.1-19.2 Section 8 Referral Fees Prohibits the giving or taking of a fee or other thing of value for a referral involving a federally related loan Un-earned fee (also called a kickback) A fee we receive but we have performed no work in exchange for receiving the fee. Real Estate Settlement and Procedures Act http://www.hud.gov/offices/hsg/ramh/res/respa_hm.cfm 111
  112. 112. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 19 Module 19.2 Violations of Section 8's anti-kickback, referral fees and unearned fees provisions of RESPA are subject to criminal and civil penalties. In a criminal case a person who violates Section 8 may be fined up to $10,000 and imprisoned up to one year. In a private law suit a person who violates Section 8 may be liable to the person charged for the settlement service an amount equal to three times the amount of the charge paid for the service. 112
  113. 113. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 19 RESPA Modules 19.1-19.2 TILA/RESPA Definition of “an Application” Financial Data Borrower’s Name Soc Income Estimated value Loan Amount ….. Prop address (will have this if refi, might not have this right away if borrower is still house-shopping.) ….. Any other info deemed necessary by the LO Real Estate Settlement and Procedures Act http://www.hud.gov/offices/hsg/ramh/res/respa_hm.cfm 113
  114. 114. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 19 RESPA Module 19.3 Take the RESPA Quiz Section 19 Module 19.4 Learn how to complete a Good Faith Estimate See instructions from HUD Instructions for Completing Good Faith Estimate (GFE) Form Code of Federal Regulations Title 24, Volume 5 114
  115. 115. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 20 RESPA Amendments in 2009 Modules 20.1 Real Estate Settlement and Procedures Act (2009 Changes) http://www.federalreserve.gov/boarddocs/supmanual/cch/respa.pdf 115
  116. 116. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 20 RESPA Amendments in 2009 Modules 20.1-20.7 GFE tolerances Violations, penalties Definition of “An Application” GFE delivery, loan term availability Changed circumstances Seller paid fees Required use Average charge pricing, volume discounting RESPA Amendments Quiz Real Estate Settlement and Procedures Act (2009 Changes) http://www.federalreserve.gov/boarddocs/supmanual/cch/respa.pdf 116
  117. 117. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 21 Module 21.1 and 21.2 Equal Credit Opportunity Act ECOA 1974 ECOA points us toward the evaluation based on creditworthiness only. Nine categories; the prohibited bases: Race Color Religion Sex Marital Status National Origin Income from Public Assistance (Age) Whether an applicant has exercised his or her rights under this act. Equal Credit Opportunity Act http://www.fdic.gov/regulations/laws/rules/6500-1200.html 117
  118. 118. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 21 ECOA Module.21.2 It is a violation to discourage an applicant from making an application for credit on a prohibited basis. Cannot ask an applicant if he or she receives alimony, child support. The applicant may volunteer such information. You must ask if he or she PAYS alimony or child support. Unmarried… ECOA requires the lender to provide a copy of the appraisal report. Application need not be in writing for this act to apply. Can we ask questions NOT related to creditworthiness? Adverse Action Form Equal Credit Opportunity Act http://www.fdic.gov/regulations/laws/rules/6500-1200.html 118
  119. 119. National Association of Mortgage Fiduciaries Jillayne Schlicke Section21 Module 21.2 Equal Credit Opportunity Act ECOA Marital Status 1. Unmarried = Single Divorced Widowed 2. Married 3. Separated Equal Credit Opportunity Act http://www.fdic.gov/regulations/laws/rules/6500-1200.html 119
  120. 120. National Association of Mortgage Fiduciaries ECOA comparison to Race Color Religion Sex National Origin Marital Status Income from Public Assistance Age Whether an applicant has exercised his or Her rights under this Act. Jillayne Schlicke Fair Housing Race Color Religion (Creed) Sex National Origin Familial Status Sexual orientation added in 2012 as a protected class in all 50 states to Fair Lending rules Disability 120
  121. 121. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 21 Module 21.3 Equal Credit Opportunity Act ECOA Quiz 121
  122. 122. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 22 Module 22.1 and 22.2 Fair Credit Reporting Act FCRA Fair Credit Reporting Act http://www.fdic.gov/regulations/laws/rules/6500-200.html Passed to ensure consumers have access to credit information used by lenders and others so that remedial steps could be taken when incorrect or outdated information remained in their file. Purpose of a credit report: Insurance, licensing, instruction from consumer, extension of credit, employment, response to a court order, potential investor risk, other legitimate business needs. Credit reports are deemed privileged info. A CRA has 30 days to respond to a disputed item Adverse Action: Name, address and phone number of the CRA, reason, and info on how to obtain a free copy of their report. 122
  123. 123. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 22 Fair Credit Reporting Act FCRA Module 22.3 Quiz 123
  124. 124. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 23 Modules 23.1-23.10 Other Federal Laws Governing Mortgage Lending HMDA Home Mortgage Disclosure Act CRA Community Reinvestment Act GLB Gramm Leach Bliley Act AKA Privacy Act GLB FTC Safeguard Rules MARS Rules Bank Secrecy Act U.S. Patriot Act PMI Act FACTA Fair and Accurate Credit Transactions Act Do Not Call Additional Federal Laws Quiz 124
  125. 125. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 24 SAFE Mortgage Licensing Act Module 24.1 The SAFE Act of 2008 SAFE = Secure and Fair Enforcement Act  Passed in order to increase uniformity, reduce regulatory burden, enhance consumer protection, and reduce fraud. Establishes the Nationwide Mortgage Licensing System and Registry. Title V SAFE Mortgage Licensing Act of 2008 http://mortgage.nationwidelicensingsystem.org/SAFE/NMLS %20Document%20Library/SAFE-Act.pdf 125
  126. 126. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 24 SAFE Act Module 24.2 “Registered Loan Originator” An employee of: a depository institution; a subsidiary that is: owned and controlled by a depository institution AND regulated by a federal banking agency OR An institution regulated by the Farm Credit Admin Title V SAFE Mortgage Licensing Act of 2008 http://mortgage.nationwidelicensingsystem.org/SAFE/NMLS %20Document%20Library/SAFE-Act.pdf 126
  127. 127. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 24 SAFE Act Module 24.2 State or Federally Chartered Depository Banks: LOs are exempt from testing and education. NOT exempt from “registration.” Register with the Nationwide Mortgage Licensing System (NMLS) and will be given a unique identifier. “Registered” LOs Title V SAFE Mortgage Licensing Act of 2008 http://mortgage.nationwidelicensingsystem.org/SAFE/NMLS %20Document%20Library/SAFE-Act.pdf 127
  128. 128. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 24 SAFE Act Module 24.2 Issuance of a License: Never revoked No felony last 7 years No felony at any time re fraud, dishonesty, breach of trust, money laundering Financial responsibility Pre-licensing education Written test Net worth and surety bond Title V SAFE Mortgage Licensing Act of 2008 http://mortgage.nationwidelicensingsystem.org/SAFE/NMLS %20Document%20Library/SAFE-Act.pdf 128
  129. 129. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 24 SAFE Act Module 24.2 LO exam: 75% to pass Can retake 3 X at 30 day intervals If fail 3 X, must wait 6 months 5 year lapse in license: must retake the test Title V SAFE Mortgage Licensing Act of 2008 http://mortgage.nationwidelicensingsystem.org/SAFE/NMLS %20Document%20Library/SAFE-Act.pdf 129
  130. 130. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 24 SAFE Act Module 24.2 Continuing Ed 3 hours Federal Law 2 hours Ethics, Consumer Protection, Fraud, Fair Housing 2 hours Non Traditional Lending 1 hour Undefined No carry-overs Can’t take the same class each year. Title V SAFE Mortgage Licensing Act of 2008 http://mortgage.nationwidelicensingsystem.org/SAFE/NMLS %20Document%20Library/SAFE-Act.pdf 130
  131. 131. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 24 SAFE Act Module 24.3 Take the SAFE Act Quiz 131
  132. 132. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 25 Dodd Frank Act Changes Module 25.1 Escrow Requirements APOR = Average Prime Rate Offering Module 25.2 Loan Originator Compensation Requirements Additional LO Qualifications under Dodd Frank 132
  133. 133. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 25 Dodd Frank Act Changes Module Module Module Module Module Module 25.3 25.4 25.5 25.6 25.7 25.8 Ability to Repay Qualified Mortgage Balloon Payment, QMs High Cost Mortgages Mortgage Servicing Appraisal Disclosure and Delivery Module 25.9 Test your knowledge! Take the Dodd Frank Act Changes Quiz 133
  134. 134. National Association of Mortgage Fiduciaries Jillayne Schlicke Section 26 Final Exam, Recap and Close Review all remaining unanswered questions. FINAL EXAM Students complete end-of-course evaluation form. Instructor provides end-of-course completion certificates. 134
  135. 135. National Association of Mortgage Fiduciaries Jillayne Schlicke Jillayne Schlicke CE Forward, Inc. National Assoc of Mortgage Fiduciaries 206-931-2241 jillayne@ceforward.com mortgagefiduciaries.com 135

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