Episode 10 - The Legal Risks of Cross-Qualification of Borrowers with Jerra Ryan - Part 1 episode artwork

EPISODE · Nov 7, 2017 · 7 MIN

Episode 10 - The Legal Risks of Cross-Qualification of Borrowers with Jerra Ryan - Part 1

from The Mortgage Compliance Insiders Podcast SeriesSM · host Roger Fendelman

Cross-Qualification = when the listing agent demands that your loan officer send a borrower's personal financial information, credit report and/or AUS findings to a competing lender prior to submitting an offer...or something like that. Just so you know, the practice may violate GLBA and the lender's own privacy policy. It may violate the lender's contracts with the GSEs. It is also very likely that an underwriting decision is taking place, invoking disclosure requirements that aren't being complied with under TRID, TILA, RESPA, required reporting that isn't taking place under HMDA and treatment/disclosures not happening under ECOA if the loan is not approved. And we haven't even touched state law violations yet. Why is this even happening? Is there a legal way to do this? Find out by listening to Jerra Ryan in this two-part series!

Cross-Qualification = when the listing agent demands that your loan officer send a borrower's personal financial information, credit report and/or AUS findings to a competing lender prior to submitting an offer...or something like that. Just so you know, the practice may violate GLBA and the lender's own privacy policy. It may violate the lender's contracts with the GSEs. It is also very likely that an underwriting decision is taking place, invoking disclosure requirements that aren't being complied with under TRID, TILA, RESPA, required reporting that isn't taking place under HMDA and treatment/disclosures not happening under ECOA if the loan is not approved. And we haven't even touched state law violations yet. Why is this even happening? Is there a legal way to do this? Find out by listening to Jerra Ryan in this two-part series!

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Episode 10 - The Legal Risks of Cross-Qualification of Borrowers with Jerra Ryan - Part 1

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This episode is 7 minutes long.

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This episode was published on November 7, 2017.

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Cross-Qualification = when the listing agent demands that your loan officer send a borrower's personal financial information, credit report and/or AUS findings to a competing lender prior to submitting an offer...or something like that. Just so you...

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