Managing QC and audit in the wake of COVID-19
As we each grapple with the daily impact of COVID-19 in our personal lives, and prayerfully remain healthy, a myriad of tweaks and changes are occurring within our industry. The difficulty is managing to multiple areas of impact, from business closings, to increasing eFilings, staff availability, to investor guidelines, and changing state and federal regulation. The future presents a real challenge for bank and mortgage originators. Now more than ever, auditing and quality control is a vital component of lending.
Managing daily origination through post closing and pre-funding necessitates a triage approach that leverages business continuity, amidst change management and risk control.
There are some key areas that at a minimum require some foresight and planning to ensure compliance:
Make certain all communications are conducted in a consistent manner that is trackable. Extra attention should obviously be focused on borrower sensitivity, consistency to ensure Fair Housing requirements are met, and clarity to guide your customer base.
As staffing availability ebbs and flows, activities and processes need to be effectively transitioned throughout your organization. Hand offs for file flow need to be carefully evaluated to avoid process gaps and errors, even if underlying processes are automated.
Change management will be of greater necessity as manual processes may increase, automated processes will be updated, and business operations overall evolve on a daily basis. Managing operational change and business continuity is critical.
GUIDELINES & REGULATION
COVID-19 regulatory mandates, and investor requirements are hitting multiple areas of the loan lifecycle. The most recent changes to facilitate origination includes:
Documentation alternatives to preclosing employment verification.
Appraisal/valuation options including appraisal alternatives, such as exterior only, appraisal waivers, and the insertion of conditional language.
A reminder that promissory note possession is required prior to loan delivery.
Servicing updates include the following efforts to promote default relief:
HUD’s suspension of face-to-face requirements on early default.
The GSEs and HUD have suspended evictions and foreclosures.
GSE payment forbearance or suspension for eligible COVID-19 borrowers.
This is the beginning of what certainly represents ongoing changes and disruption to your lending processes. QMS is here to help…. As your organization diligently works to meet the evolving COVID-19 challenges, having a dedicated industry partner complete audit functions and perform required QC can make a tremendous difference. Let us assist in keeping your team compliant and managing risk exposure during these unprecedented times.
Quality Mortgage Services (QMS) has always placed a premium on customer service. We differentiate our quality control offering by placing the customer first and evaluating all of our products and services from the customer perspective. As COVID-19 continues to impact our industry, QMS is here to help you maintain loan quality and risk mitigation, so your leadership team can focus on change management and strategic foresight. Our unique set of solutions consists of professional quality control and audit support, including pre-funding, pre-purchase due diligence, post-closing and early payment default, as well as numerous other tools and audits in the QMS suite. Visit us at www.qcmortgage.com to see how our team can assist you and your teams in navigating this difficult time for the industry and homeowners.
QMS is an active MBA member that values our customers and honors their needs. To that end, we strive to offer thought leadership and guidance on issues, such as COVID-19, that impact homeownership and diversity in lending to help support the ongoing evolution of our industry.