Non-QM Lending - Mortgage Bankers and Brokers Association ...
Non-QM Lending
MBBA-NH & MAMP Compliance Conference
April 20, 2016
Ben Niles, Master CMB Housing Advocate
Mortgage Banking Instructor
Disclaimer
These statements are solely my opinions based on 44 years of mortgage finance experience and recent Non-QM research.
Proprietary information, do not distribute or use without permission of MBBA-NH.
Non-QM Trends
Agenda
1) Non-QM Risks 2) Non-QM: "A Paper" vs "Sub-Prime" 3) How to Identify a Wolf in Sheep's Clothing 4) The New Subprime Aggregators 5) New Entrants
Proprietary information, do not distribute or use without permission of MBBA-NH.
Non-QM Trends
Agenda
6) Funding Non-QM Loans 7) Legal and Regulatory Issues of Sub-Prime, Low Doc & No Doc Loans 8) Lending Reps & Warrants 9) To Lend Non-QM or Not
Proprietary information, do not distribute or use without permission of MBBA-NH.
Non QM Risks
Penalty for Violating QM: 1) 3 Years Financing Charges 2) All Fees Paid at Closing 3) Legal Fees 4) Regulatory Fines (unspecified- no limit?)
Industry Estimate of Cost of Violation: 1) $100,000 on Average Loan 2) $200,000 on Jumbo Loans
The Big Unknown: No Judicial Case-law or Precedent
Proprietary information, do not distribute or use without permission of MBBA-NH.
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