It looks like lenders are really trying to insure consumer confidence these days!!
HOMECOMINGS FINANCIAL, LLC
f/k/a HOMECOMINGS FINANCIAL NETWORK, INC.
DECLARATION OF FAIR LENDING POLICY & PRACTICES
Fair Lending Policy
Homecomings Financial, LLC (Homecomings Financial) is committed to the principle of providing access to mortgage credit for all people, regardless of race, color, religion, national origin, age (provided the applicant has the capacity to enter into a binding contract), sex, handicap, familial status, civil union, domestic partnership or marital status, sexual orientation, gender identity or expression, military status, the exercise of any right under the Consumer Credit Protection Act or the fact that all or part of the applicant's income derives from any public assistance program, and regardless of where the applicant resides, will reside, or where the residential property to be mortgaged is located.
Homecomings Financial does not tolerate fraudulent activity or any violations of the fair lending laws. Where evidence of fraud or fair lending issues is brought to light, whether through file reviews, statistical analysis or otherwise, we take appropriate action with respect to our employees and/or the brokers at issue.
RESPONSIBLE PRACTICES
Homecomings Financial has established the following standards for responsible lending:
- No high cost loans. Homecomings Financial's policy is not to originate any loans that would be considered "high cost" loans under the federal Home Ownership and Equity Protection Act ("HOEPA") or similar applicable state laws. Homecomings Financial's prohibition on "high cost" loans also applies to home purchase loans and lines of credit, even though such loans are not covered by HOEPA.
- No mandatory arbitration. Homecomings Financial does not originate any loans that contain mandatory arbitration clauses.
- No Increased interest rate upon default. Homecomings Financial does not originate loans that provide for an increase in the interest rate after default.
- No Single premium insurance. Homecomings Financial does not originate loans that finance single premium credit life, credit disability, credit unemployment, or any other pre-paid life or health insurance, directly or indirectly.
- Prepayment options. Homecomings Financial offers loans with and without prepayment penalties. Borrowers may elect to apply for any of Homecomings' loans without prepayment penalties.
- Fair and clearly disclosed loan terms. Homecomings Financial requires that loan terms be clearly disclosed to the borrower in accordance with state and federal law.
LOAN PROCESSING AND UNDERWRITING
In order to ensure that each borrower is offered the most affordable loan possible, Homecomings Financial's automated loan evaluation system uses the information that is input by the broker or loan officer to match each applicant to the highest grade mortgage products offered by Homecomings Financial for which he or she qualifies, based on their credit score, loan to value ratio and other factors.
Recognizing the central role of underwriting and appraisal standards in the mortgage lending process, Homecomings Financial promotes the flexible use of these standards. To ensure that standards are applied as reasonably as possible, Homecomings Financial keeps abreast of the discretion provided to primary lenders under the guidelines developed by Fannie Mae, Freddie Mac, conduits and private mortgage insurers (third parties).
An element of judgment and subjectivity enters into all underwriting decisions. To give the widest possible latitude to good judgment, the underwriting guidelines are developed to be as flexible as possible.
The responsibility for reviewing these guidelines and understanding their application to a changing population belongs to both the third parties that develop the guidelines and the primary lenders that apply them.
BROKER RELATIONSHIPS
Broker Approval
Homecomings Financial requires every broker seeking to do business with us to submit a detailed application package. We conduct background checks and evaluate each application carefully.
Broker Compensation
Homecomings Financial has established and imposed a Maximum Broker Compensation Cap.
Broker Monitoring
Homecomings Financial does not tolerate fraudulent activity or any violations of the fair lending laws. Where evidence of fraud or fair lending issues is brought to light, whether through file reviews, statistical analysis or otherwise, we take appropriate action with respect to the brokers at issue.
November 2007
All of these things should have been in place allready anyways!!!
~Kris Krajecki
Fox Valley Mortgage
Huntley , IL #1 Mortgage Man
;)
;)
