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Automated Compliance Engine
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- Making Home Affordable ACE
'Making Home Affordable' ACE
The regulatory and program requirements surrounding the Obama mortgage plan are complex and challenging to implement. The 'Making Home Afforable ACE (automated compliance engine) helps lenders, loan servicers, investors and borrowers’ agents who are working toward ensuring working Americans can afford to stay in their homes.
The 'Making Home Affordable' ACE is a turnkey solution that identifies and describes compliance exceptions relating to important consumer protection violations; Fannie Mae and Freddie Mac (the GSEs) predatory lending policies; the Home Affordable Refinance program requirements; and, the Home Affordable Modification program requirements.
Regulatory and Program Requirements
Mavent’s 'Making Home Affordable' ACE evaluates loans for compliance with the following regulatory and program requirements:Truth In Lending Act (TILA) – Mavent recalculates important disclosed information (including the amount financed, the APR and finance charge) and verifies that the disclosures comply with TILA tolerances. Mavent also validates that the rescission period for the loan is in compliance with TILA timing requirements. Loans that violate TILA can result in rescission (effectively the borrowers right to cancel the loan), defenses to foreclosure and statutory damages.
HOEPA and High Cost – Mavent analyzes loan terms and classifies fees under applicable federal (HOEPA or Section 32), state and local predatory lending laws to determine whether a loan’s APR or points and fees exceed any regulatory threshold limits. Loans that exceed a threshold may not be eligible for purchase by the GSE’s. Furthermore, loans that exceed a threshold may be predatory and subject the lender (and in some cases investors) to substantial liability, including damages that can greatly exceed the value of the loan.
GSE Requirements – Mavent evaluates the loan to make sure that it is saleable to government-sponsored entities Fannie Mae and Freddie Mac. If a loan does not meet Fannie Mae’s or Freddie Mac’s unique requirements the seller can be forced to buy back the loan. Mavent has worked with both Fannie Mae and Freddie Mac to ensure an accurate review of loan information for compliance with each GSE’s proprietary 'points and fees' test and other requirements.
Home Affordable Refinance Program Requirements – Mavent reviews a loan for compliance with critical aspects of the eligibility requirements of the Fannie Mae Refi Plus™, the Fannie Mae DU Refi Plus™ and the Freddie Mac Relief Refinance MortgageSM programs, including restrictions relating to interest accrual, amortization, lien position, loan term, loan purpose and fee limitations.
Home Affordable Modification Program Requirements – Mavent reviews seasoned loans for compliance with critical aspects of the eligibility requirements of the Home Affordable Modification Program so as to identify loans that qualify for streamlined modifications.
Making Home Affordable ACE features:
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