Time is up: Are you prepared for Fannie Mae’s new prefund QC necessities?

Mortgage high quality management is once more high of thoughts for lenders, partially as a result of wave of loan-repurchase requests from Fannie Mae and Freddie Mac earlier this yr. Greater mortgage volumes in 2020 and 2021 led to proportionally extra repurchase requests, and the trade is taking one other take a look at their danger mitigation methods in consequence.

“It’s truthful to say that the trade routinely has, particularly because the 2008 credit score disaster, been centered on danger,” mentioned Kristin Broadley, chief innovation officer at QC Ally. “It by no means hurts to reassess, and I believe having the repurchases come by at quantity helped individuals hone in and concentrate on it. I believe everybody’s conscious that defect charges are up and individuals are dedicated as an trade to creating certain that they’re originating good loans.”

Fannie Mae’s new QC pre-fund necessities

New Fannie Mae QC prefunding necessities have supplied one more reason for lenders to reassess their high quality management and danger mitigation methods. The prefunding necessities, introduced in March, will change into lively as of September 1, 2023.

In accordance with Fannie Mae, the objective of those new prefunding necessities is to “improve mortgage high quality, scale back credit score danger, and safeguard the general stability of the lender, Fannie Mae, and the general mortgage market.”

The brand new necessities imply lenders should full a minimal variety of prefunding QC opinions every month. The evaluation should be performed by individuals with no involvement within the processing and underwriting choice of the mortgage being reviewed. And the lender’s mortgage alternatives should equal, at minimal, the lesser of both 10% of the prior month’s whole variety of loans originated or acquired, or a complete of 750 loans.

“Fannie Mae is specializing in what we at QC Ally prefer to name the ‘Energy of Prefund,’ and that’s that when you transfer your QC into your origination, you will get far more strategic with regards to remediating defects in actual time and figuring out traits,” Broadley mentioned. “When you may have a prefund evaluation that’s structured to establish alternatives, efficiencies and defects in actual time, it’s an instantaneous capacity to establish and remediate traits earlier than you incur legal responsibility, as a result of that mortgage has not closed but.”

Prefund opinions additionally enable lenders to work benchmarking, strategic high quality assurance alternatives and element opinions into their origination course of. This implies government leaders can acquire confidence concerning the certainty and high quality of their manufacturing course of.

“The flexibility to qualify of us and really feel assured in the way you’re qualifying all of them stems from having certainty round your manufacturing course of, and QC and QA within the prefund house will get you there quicker,” Broadley mentioned.

Are you ready?

With so little time till the September 1st efficient date, lenders ought to have already got taken motion to arrange for the modifications, together with:

  1. Looking at how the foundations will influence their present QC coverage and process
  2. Figuring out how they need to construction their prefund opinions and whether or not they need to deal with these opinions internally or externally
  3. Making a evaluation cadence with a view to have sturdy governance and monitoring within the prefund house

By way of whether or not to carry out a element evaluation or full-file evaluation, probably the most environment friendly technique is to do a mixture of each, if attainable, Broadley mentioned.

In a element evaluation, you isolate a qualifying attribute of the mortgage file to pattern for evaluation. As a result of the element evaluation focuses on a single piece of the origination course of, it’s very environment friendly and efficient when the pattern is structured appropriately.

A full-file evaluation is a little more sturdy and requires extra assets however offers you a holistic take a look at your mortgage file and course of. It may well help you take a look at an underwriter or LO or offer you a statistical pattern of your general manufacturing for any given month.

“Should you mix each the total file to know how your manufacturing course of is being facilitated overarchingly, you may then leverage these element opinions for the mortgage traits that you simply discover dangerous,” Broadley mentioned. “Then, you actually have a holistic take a look at the well being of your manufacturing course of.”

Leveraging a third-party QC knowledgeable

The primary problem of those new QC prefund necessities shall be scale, as 10% of the earlier closed month manufacturing or as much as 750 loans is usually a lot. Due to the useful resource shortage and right-sizing of the trade from a manufacturing perspective, it may be tough to allocate the appropriate variety of assets to deal with these necessities. Many lenders could flip to a third-party QC agency to facilitate the opinions.

That’s the place QC Ally can step in to assist. The agency is made up of material specialists on QC, evaluation and audit, and its staff might help replace coverage and procedures, work out a governance and monitoring program and assist with the QC audits themselves.

Moreover, working with QC Ally provides a variable price versus a set price to a lender’s course of.

“If you wish to scale responsibly — and this market will change, it’s a cyclical market — it’s onerous so as to add good assets rapidly,” Broadley mentioned. “Going to a topic [expert] in any single space means that you can scale and facilitate these issues that you need to do with out including price or danger to your backside line.

To study extra about working with QC Ally, go to https://qcally.com/.