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Apache is functioning normally

December 21, 2023 by Brett Tams

It was late 2022 and Mike was feeling the pressure. Mortgage rates had climbed close to the 7% range and he was determined to remain competitive on pricing with rival loan officers in North Carolina.

But there was a problem: pricing exceptions, in which the lender takes the hit, were becoming scarce at his company. So he did what a lot of retail loan officers in the industry were doing — Mike would reclassify a self-generated lead as a corporate-generated lead, thus slashing his compensation from 125 basis points down to as low as 50 bps, giving him a low enough rate to win the client and eventually close the deal. His manager and company bosses knew that he and other LOs were lying about where the lead source came from, he said.

The lower comp rate stung. After Mike paid his loan officer assistant, he was clearing just 40 bps. Still, it was better than nothing. After all, tens of thousands of loan officers had already exited the industry because they couldn’t generate enough business.

“At this time, I didn’t really think of it as an ethical issue,” Mike, whose last name is being withheld for fear of retaliation, told HousingWire in an interview in late November. “But it started to wear on me to where it was like, okay, I’m getting price-shopped left and right. I’m feeling the pressure to cut my pay, because when I do it, and my agent partners, they see that I do that, and then they’ll tell people they refer to me. ‘Hey, he can dig deeper if he really has to.’”

Mike continued: “Well, doesn’t that smack of bad faith if I’m not offering them my best price from jump? I would get people saying to me, ‘I’m not going to go in with you. I don’t feel comfortable with you, because you tried to get me to go for a higher pricing first, and then only offered a better deal once I told you I had another offer.”

Mike said he left that lender in early 2023 as a result of the ‘bucket game’ and refuses to manipulate where lead sources are coming from at his current shop.

“It’s a race to the bottom,” he said of the practice.

Over the past two months, HousingWire has interviewed more than a dozen loan officers, mortgage executives, attorneys and also reviewed several companies’ loan officer contracts and text messages between recruiters and prospects to shed light on the growing issue of pricing bucket manipulation, which critics say distorts market pricing and could represent a violation of fair lending laws.

It’s unknown how many retail lenders are engaged in the practice of falsifying lead sources to lower loan officer pay, but industry practitioners say it’s widespread, and in most cases, reclassifying leads into different pricing buckets before they lock is not permitted by the Consumer Financial Protection Bureau’s rules under Regulation Z.

It’s also unclear whether the CFPB is policing the practice; HousingWire could find no record of enforcement actions taken, and the agency’s audits are not public record.

Evolution of the LO Comp rule

In the wake of the housing crash in 2008, the CFPB created new rules that reshaped how loan officers were compensated. The architects of the new rules wanted to prevent loan officers from taking advantage of borrowers, which was a common occurrence in the days leading up to the Great Recession.

Under an updated Regulation Z, lenders could no longer pay loan officers differently based on terms of loans other than the amount of credit extended. In theory, this means loan officers provide the same service and pricing on loans, reducing the risk of steering.

“LOs also can’t get paid on proxies, and they define proxies to be pretty straightforward: some factor that correlates to terms over a significant number of transactions, and the LOs have the ability to change that factor,” said Troy Garris, co-managing partner at Garris Horn LLP.

But the CFPB did allow loan officers to be compensated differently based on lead sources, which do not fall under the category of terms or proxies and are neither a right or an obligation.

For example, when an existing customer calls the lender’s call center for a new mortgage or refinance, and the lender redirects the loan to the LO, “the LO gets paid less because it was sourced from the company, and it is less work for the LO,” said Colgate Selden, a founding member of the CFPB and an attorney at SeldenLindeke LLP. When it’s an outside lead, “the LOs generated the lead themselves; they are spending time marketing to new borrowers, so they get paid more.”

Attorneys told HousingWire that in the current marketplace, violations of LO Comp rules can arise when lenders and LOs alter compensation by changing the lead source after the initial contact with the borrower to lower their rate and secure the deals. Regulation Z generally does not allow LOs to change which lead source was used.

But, in today’s competitive market, “I do think there’s an incentive, especially on the LO side, to find ways to do something different – and probably also for companies to decide to take more risk,” said Garris. “We believe this is happening because people are frequently asking if there’s a rule change.”

How the ‘bucket game’ works

LOs who spoke to HousingWire said managers often told them they wouldn’t get pricing exceptions on deals, so if they wanted to gain an edge it would have to come out of their pay. Three loan officers at three different retail lenders described it as a feature of their lender’s business model.

“You feel out a prospective client during the initial conversation, get a sense of whether they know how everything works, if they’ve spoken to another lender, if they’re going to shop you, right? And you quote them the best possible rate you could give them that day, knowing that you’ll put them in a bucket just before lock,” said one Wisconsin-based LO. “It doesn’t really matter what you quote them in the initial conversation as long as you can get it below competitors around lock time…either through a pricing exception or the bucket [manipulation].”

One top-producing California-based loan officer said she was excited when a top 35 mortgage lender tried to recruit her with the promise of multiple pricing buckets. Having the buckets would provide her flexibility that her current lender didn’t offer, she thought at the time.

“What the [recruiting] company told me explicitly was the loan originator, when they go to lock the loan, they check a box – is it self, branch or corp gen? And you only get to check one box, but it’s the loan officer’s choosing, not the branch,” she said. “So the loan originator is choosing, not the branch that says I’m going to give you a lead and this is the comp for it. Not the corporate advertisement or online group that says you’re getting this lead from us and here’s documentation that it occurred and now you’re going to get less comp. It’s the ultimate in legalized fraud. Because it’s not true.”

These days, many lenders have pricing buckets for corporate-generated leads, branch leads, builder leads, marketing service agreement (MSAs) leads, internet leads from aggregators and more. In and of itself, it’s legal, provided the lead really did come from the source and it’s diligently tracked by the lender.

Loan officers and mortgage executives interviewed by HousingWire said some lenders justify the practice of manipulating the buckets by telling LOs it’s legal and they’ve been audited by the CFPB, which has not found any wrongdoing. Several executives accused of the practice declined to comment on the record about pricing bucket manipulation, though they all said they track leads as required and are in full compliance with the law.

Selden, the former CFPB attorney, said that LOs are telling borrowers who complain about high mortgage rates that companies are “running a special offer.” Borrowers are directed to the company’s website, where, by indicating the LO name, they supposedly qualify for a special deal with a lower rate. In reality, at lenders without adequate controls to prevent lead source manipulation, this shifts the source from self-generated to an in-house lead.

LOs interviewed by HousingWire said that in some cases they would be able to change the lead referral source themselves, and in other cases they’d need a manager to alter the lead source in the loan origination system.

While many instances of price bucket manipulation were directed by managers, LOs would also self-select, said Mike.

“Most of the time you don’t have a loan estimate from a competitor, you’re just afraid that you’re going to lose it because you’re so embarrassed about the rate. And that’s why a lot of my comrades… were going to the corporate-generated lead bucket before they even confirmed that they had to. Partly because you wanted to lead with your best price.”

Steve vonBerg, an attorney at law firm Orrick in Washington, D.C., worked as a loan officer and underwriter for seven years. He emphasized the potential trouble for lenders and LOs inaccurately classifying the lead source.

“Often, a [CFPB] examiner would see if the lead channel changed later in the process. That could be legitimate: the borrower starts working with an LO, and it’s a self-sourced lead for that LO, but then decides to buy a home in a different state in the middle of the process; the second LO that it has to be transferred to has now an internal-company referral, and so the lead source would legitimately change,” vonBerg said. “But, if there isn’t a legitimate reason for the lead source changing midstream, that would be fairly easy for an examiner to identify.”

“It’s wrong”

Victor Ciardelli is frustrated by the bucket game. Deeply frustrated. The Guaranteed Rate founder and CEO says he is losing money and loan officers to rivals because of a business practice that he says is flagrantly illegal, pervasive, and does not appear to be slowing down anytime soon.

Some rival retail lenders, he says, are creating up to a dozen pricing buckets for their loan officers. The tiered nature of the bucket comp structure in many cases — self generated being the highest at up to 150 bps, 100 bps for another ‘bucket,’ 80 bps for another, down to 60 bps, 40 bps and sometimes all the way to zero — proves that it is a deliberate business strategy, he said.

“It wasn’t intended that the loan officer at the time that they’re talking to the consumer and quoting them a rate, that the loan officer can put the consumer in any bucket they want,” he said in an interview with HousingWire. “But that is exactly what’s happening. What’s exactly happening is the fact that there’s all these different pricing buckets for a lot of these different companies out there. And that the loan officer is allowed to go in and offer the consumer whatever rate based on what the loan officer wants.”

He argued that LOs are maximizing their personal income per borrower.

“It’s no different than what happened prior to Dodd-Frank, where it was the wild, wild West and people were playing games with customers on rates and fees,” said Ciardelli. “It’s the same thing today. There’s no difference except the fact that there’s a law in place that tells the mortgage company and the individual loan officer. And the loan officers know that they’re violating the law. It’s greed.”

Ciardelli says the rival CEOs — he declined to name individuals and said it’s an industry-wide problem — are establishing these buckets and know “full well that the bucket is put in place in order to lie about where the lead source is coming from.”

They have an obligation to know where the leads are coming from, that the loan officers are putting them in the appropriate bucket and that they are being tracked, he said.

“The loan officer may take a hit on that loan, and may make less on that loan, but the company themselves doesn’t take the hit, their margin stays the same. So the company CEO is happy, because they’re like, ‘I’m giving my loan officers all this flexibility to go out and be competitive and win deals. And they’re going to win more deals than anybody else out there, because they’re going to be able to slot the individual borrower into these different lead channels. So the individual CEO is making all the money. They’re the ones killing it.”

Ciardelli says he asked about the bucket pricing game and attorneys all told him no, it’s not legal, he said.

“I’ll play by whatever the law is…But when the rules are set up to be a certain way and people are not following the rules, then that’s a problem.”

Two other executives at large retail lenders also said they’ve lost loan officers to competitors who are sanctioning, if not directing, the manipulation of pricing buckets.

“The LOs get told this is legal, it’s just pricing flexibility so they can compete, and they have a compliance team that monitors it,” said one executive at a regional lender in the South. “Obviously that’s not true… What’s happening is they [the lenders] are pricing high and basically forcing the LOs to cut from say 150 [basis points down to 50 [basis points] on some loans because otherwise they just won’t do enough business. It’s a feature, not a bug, as they say. We asked our attorneys if we could do this and they told us absolutely not.”

The Mortgage Bankers Association (MBA) is aware of the issue. The organization asked an outside attorney from Orrick Herrington & Sutcliffe LLP to study the permissibility of the practice. In a letter sent to members in February 2023, Orrick advised MBA members that changing the lead source of a loan after beginning work on the application in order to make a competitive pricing concession “is not permissible.”

The letter has had little meaningful impact, sources told HousingWire. If anything, the practice has increased over the last year.

Fair lending concerns

Another repercussion in the market is that savvy borrowers gain access to lower rates when lead sources are manipulated. Less educated applicants could be quoted higher rates for the same loan, raising concerns about fair lending practices.

But this argument prompts a broader discussion on the efficacy of the LO comp rule, with divergent opinions on the matter.

“I used to be an MLO for seven years. I was in the industry in the 2000s until it melted down, and then I ended up going to law school because I had lost my job. I originated hundreds of loans myself, and personally, I think overall the rule is a good rule,” vonBerg said.

vonBerg elaborated: “Under the old regime, LOs were not incentivized to offer their consumers the best loan and best pricing for them. They were incentivized to give them the loans and pricing where they would make more money. Although it has some issues that should be corrected, I think the LO comp rule makes a lot of sense, in that it removes a gigantic conflict of interest.”

Not everyone shares this viewpoint.

“The LO comp rule was designed to prevent steering to high-cost loans. And really, those things don’t exist anymore. We can’t put borrowers in homes that they can’t afford,” said Brian Levy, Of Counsel at Katten and Temple, LLP.

According to Levy, the rule creates “a tremendous amount of anxiety for the mortgage lending industry that doesn’t benefit consumers in any meaningful way.”

“The industry is frustrated. They’re unable to easily reduce prices. For example, in the past, before the rule was around, LOs were able to take less as a commission, just like any other salesperson – a car salesperson – to make the deal work. That’s illegal now for loan officers. The mortgage company can make that decision [of lowering their margins and reducing rate], but the loan officer cannot.”

Levy noted that some consider the LO comp rule to be a de facto fair lending rule.

“But we already have fair lending rules. The idea that if the loan officer is discounting their fees, they would end up discounting on a discriminatory basis would already be problematic under existing law, so you don’t need the LO comp rule to make that illegal. It’s already illegal to discriminate in pricing. That said, it’s not illegal for people to negotiate just like you can negotiate a car price.”

The CFPB has also taken issue with other forms of pricing concessions over the last year. In the summer of 2022, the agency reported that pricing exceptions, in which the lender offers a discount, had harmed protected classes, who were less likely to be offered discounts.

Where’s the CFPB?

Multiple sources said the CFPB audits about 20% of mortgage lenders per year, and because of the prevalence of this practice, would undoubtedly have come across lead bucket pricing manipulation by now.

Why there hasn’t been any enforcement to date or whether there’s a future enforcement action is just on the horizon is hard to know.

The CFPB, which is undertaking a broad review of the LO Comp rule, declined to make anyone available to speak on the issue.

“We cannot comment on any ongoing enforcement or supervision matters,” said Raul Cisneros, a Bureau spokesperson. “Those who witness potential industry misconduct should consider reporting it by going here. Additionally, we always welcome stakeholder feedback on any of our rules, including the loan officer compensation rules.”

In early 2023, the CFPB initiated a review of Regulation Z‘s mortgage loan originator rules, which include certain provisions regarding compensation. However, industry experts do not foresee substantial changes or anticipate the CFPB addressing the issue of lead source manipulation.

“In fact, there haven’t been a lot of public enforcement actions by the CFPB in several years [on the LO comp rule]. But having said that, we used to complain that the CFPB was participating in regulation by enforcement, and now they seem to be regulating by supervisory highlights,” Kris Kully, a law firm Mayer Brown partner, said.

The CFPB’s latest move regarding the LO Comp Rule was to issue a supervisory highlight in the summer stating that compensating an LO differently based on whether a loan product was originated in-house or brokered to an outside lender is prohibited.

Industry practitioners said the lack of enforcement from regulators has allowed the pricing bucket manipulation practice to flourish, creating an uneven playing field.

“You have all these companies that all of a sudden are starting to get a free pass,” Ciardelli said. “They’re like, ‘I’m not having any audits. I’m not having anybody come and say anything to me. I mean, nothing’s really happening. I’m pretty much unscathed here.’ And year after year goes by, there’s no auditors, there’s no issues. And then they start to move the needle on how they’re running their business and decisions they’re making. And they have less fear of the government, less fear of the existing rules that are in place, because the rules that were set up are not being enforced.”

Another mortgage executive speculated that the pricing bucket games will come to an end not because of CFPB enforcement, but because loan officers and executives will battle it out in court.

“I’ve got calls from loan officers who feel like they’ve been pushed into a lower commission scale than they thought they were going to get to start with,” he said. “I hired somebody from a well-known lender. When they hired her, they told her, ‘Hey, these are what the rates are and this is what the commission is.’ When she got over there, the rates they were quoting were the lead-based rates, not the hundred-based points they were promising her… I don’t think the enforcement will come from the CFPB. I think it’ll come from some type of lawsuit like that.”

The lasting impact of LOs cutting their comp to win clients and close deals won’t be clear until mortgage rates meaningfully fall for a sustained period.

But many fear that the genie can’t be put back in the bottle.

“We’ve done this so much that they’ve built it into their pricing,” said Mike, the loan officer in North Carolina. “They are pricing things higher, assuming that we’re going to cut our pay, and protect their margins. So to me that’s the bigger issue for us selfishly, is we start doing that, and it’s going to become the norm. The pricing system and everything is going to assume that we’ll do that.”

He mused that RESPA guidelines prohibit an LO from buying a Realtor partner a Big Mac after a closing but lying about a lead source is not policed.

“Personally being an LO, the biggest issue to me is, they’re screwing with us and just… That’s how all these shops are finding a lifeline to keep their doors open. ‘We don’t have to pay them 100 bps, we can just pay them 50, and they’ll take it on the chin.’ And it’s like, yeah, we’ll take it on the chin. Many of us are using the heck out of our credit cards right now to survive. It’s not cool.”

Apache is functioning normally

December 14, 2023 by Brett Tams

Reader Michael wrote in and asked:

At the beginning of inflation/rate hike cycle, everything I read said invest in stocks and real estate (and TIPS) to beat inflation. It sure doesn’t feel like stocks beat inflation but I haven’t run the numbers… Can you show how accurate these suggestions were and what, if anything, did beat inflation the past 2 or 3 years?

Michael

What a fantastic question. Let’s answer it today. We’ll need to take a few baby steps to answer Michael’s question.

What time frame are we going to look at (and why)?
What asset classes are we going to look at (and why)?
What tools can we use to look at those asset classes and compare their performance?

What’s Our Timeframe?

We must start by determining a “before” and “after.” Are we looking at inflation? Or the Fed’s interest rate hikes? A combination of both?

The current jumble of inflation and interest rates is undoubtedly connected to COVID-19. The Federal Reserve swiftly lowered interest rates in response to the pandemic’s economic slowdown and printed a few trillion dollars.

To answer today’s question, we should start prior to that period. January 2020 makes sense. For an end date, we’ll pick right now – December 2023. Here’s how interest rates (in orange) and inflation (purple) have changed over time. For ease of comparison, the inflation line shows a total increase of 19.03% in the past 36 months.

What Asset Classes Are We Looking At (And Why)?

Specifically, Michael asked about stocks, real estate, and TIPS** in his question.

TIPS are Treasury Inflation-Protected Bonds. These bonds provide a small nominal return plus a variable return based on rates of inflation. They are, as the name implies “inflation-protected” and, in theory, should not have been negatively affected by recent inflation.

We must also look at the most basic, inflation-exposed asset: cash. I also want to look at traditional bonds and commodities.

Most bonds aren’t TIPS. They’re not inflation-protected. In fact, inflation is a bond investor’s worst nightmare. The cashflow from a bond is guaranteed to be fixed. Inflation guarantees the value of those fixed dollars slowly decays. Not good.

Commodities – like oil, gold, timber, pork, etc. – should, in theory, rise with inflation. As prices rise around us, the price of commodities should rise too. While the magnitude of commodity inflation might not match CPI data 1-to-1, we *should* see some correlation.

The Results

Remember: our inflation figure is 19.03% over this time period. In comparison, our six asset classes have performed:

Cash = +6.33% (in purple below)
Stocks = +49.32% (orange)
Real estate = +3.59% (blue)
TIPS = +11.17% (green)
Bonds = (-5.27%) (pink)
Commodities = +42.36% (brown)

Back to Michael’s original question:

Stocks provided a legitimate real return (despite 2022 being a bad year). Take it with a grain of salt, though. I’m not a proponent of using a 3-year stock market return to prove an investing idea – stocks are just too volatile. Today’s article is a special case based on the inflation/interest rate timeline we chose.
Real estate got crushed. Some of you might be thinking, “Aren’t houses and apartments crazy expensive?! How can real estate be doing poorly?” For today’s purposes, we’re using Vanguard’s most diversified real estate index fund as our measuring stick. That fund includes various commercial real estate sectors, many of which got 1) crushed by COVID and then 2) got similarly throttled by the interest rate hikes of 2022. It’s been a tough period for real estate investors.
TIPS “only” returned 11.17%, despite the promise they’d keep up with inflation. What gives?! The main explanation is, once again, rising interest rates. TIPS should be thought of as two-products-in-one. The first product is a normal bond with a fixed nominal return. The second is a variable aspect that protects against unexpected inflation. While the second portion is doing its job, the first “normal bond” portion has been negatively affected by rising interest rates just like all other bonds (in pink). TIPS are doing what they’re meant to do…but that doesn’t mean TIPS investors are excited about it. In fact, if you compare TIPS (+11.17%) to normal bonds (-5.27%) the difference is pretty close to the overall rate of inflation, which is what we’d expect.
Commodities are up 42.36% – wow! But when I see that commodities plot, I see volatility! Plus, commodities are not income-producing assets. That’s the main reason I don’t own commodities, and not even today’s graph is going to change my mind.
Finally, we have cash providing a slow, steady 6.33% return. The lesson is clear: cash loses ground to inflation. Period. Cash is vital to meet your near-term financial needs. That cash should be parked somewhere earning ~5% right now. But that’s not a long-term solution, nor a reason to be overexposed to cash right now. Long-term assets need to be elsewhere, earning a real return above inflation.

Michael, thanks for the awesome question. Hopefully these lessons help us out some time in the future.

Thank you for reading! If you enjoyed this article, join 7000+ subscribers who read my 2-minute weekly email, where I send you links to the smartest financial content I find online every week.

-Jesse

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Apache is functioning normally

December 8, 2023 by Brett Tams

As many college students will attest, regularly buying food on campus is not only expensive, but often unhealthy. Buying your lunch for 10 dollars a day at the fast food restaurants, pizza joints, and coffee shops on campus can really add up, and most have limited healthy menu options. Taking the time to plan out your lunches and pack healthy meals for college students can make a huge difference in your energy levels throughout the day. Best of all, there are easy meals for college students that you can whip up on a budget.

The following meal plan shows how to eat on a college budget and offers healthy lunch recipes and easy meals for college students. The guide features tips from Jacqueline de Grave, a former student and college athlete who is passionate about cooking and eating well on a budget, and it’s also been reviewed by Kathryn Alp, a registered dietitian.

Monday

Rice and Beans

How to eat on a college budget starts with this quick and easy meal that you can make in a big batch a night or two in advance. It’s just what you’re looking for on a busy week with back-to-back tests and papers. Choose brown rice to hike up your fiber intake and add all sorts of veggies like corn, avocado, tomatoes and peppers for even more nutrition and flavor. Black beans and kidney beans work well, but you can also try other varieties like navy, white or chickpeas. Bean dishes can be perfect healthy meals for college students—and they can be done on a college budget.

Tuesday

Super Salad

It’s time to revamp your tired bowl of greens by topping it with tasty sources of protein and fiber. In addition to your favorite fruits or vegetables, try adding chickpeas, chicken breast, canned tuna or a sliced hard-boiled egg to keep you full throughout the day as you go from class to class. Hemp hearts are another great source of protein that are delicious sprinkled on top of salads. You may even be able to throw one of these together at your cafeteria’s salad bars when you’re on the hunt for easy meals for college students.

One of de Grave’s creations is a super simple orzo pasta salad with ground turkey, veggies, and feta cheese.

“Salads don’t have to be boring,” de Grave says. “I love to have fun mixing up ingredients that vary from pasta salads, chickpea or bean salads, to chicken salad sandwiches or chicken salad on a bed of greens. As long as you are willing to get creative with your ingredients, salads can take on many shapes and flavors and be perfect for light snacks or heartier meals that are easy to carry around.”

Wednesday

Pita Pockets

Sounds like the perfect budget meal to accompany a marathon study session, right? You can also put it on your list of healthy meals for college students. Variations include marinated tofu for vegetarians or sliced chicken breast or pork chop for meat eaters. Stuff the pita with bean sprouts, cucumbers, tomatoes, onions, avocado, and Greek yogurt and voila: You’ve got a quick, easy lunch that’s cheaper and healthier than an sandwich or burger at any campus fast food joint. Go ahead and get creative with your fillings.

“I sometimes replace the pita with romaine lettuce,” de Grave says. “Topping it with veggies, chicken, ground turkey, or chicken and homemade dressings is a super simple way to throw together a quick and affordable meal.”

Thursday

Egg Salad and Tuna Sandwich

How to eat on a college budget? Look no further than this mashup of two classic (and inexpensive) sandwich toppers: egg salad and tuna. You can splurge on your favorite veggie toppings. Use low-fat mayonnaise or Greek yogurt and hearty whole grain bread to make this an even healthier option.

“Carbs provide us with the only source of fuel for our brains,” Alp says. “If you eat enough high-quality carbs like whole grains, fruits and vegetables—that’s going to be your brain food,” she adds.

Friday

DIY Fresh Spring Rolls

These are a little bit more time consuming to prepare, but totally worth it if you’re looking for healthy meals for college students. Simply roll up vegetables and your favorite protein in rice paper, and serve with your favorite dipping sauce. You can use any filling you like including chicken breasts, avocado, or cherry tomatoes. Tofu is a great alternative because it can be cheaper than meat and can absorb any flavor, making it very versatile.

Daily Snacks

When learning how to eat on a college budget, it’s important to curb your hunger with healthy snacks throughout the day. For a well-balanced snack, Alp recommends including a food high in protein or fiber combined with carbs from fruits or vegetables. Need a few ideas to get you going? Get started with these:

Healthy Granola Cookies

Granola-based cookies can be tailored to all taste buds. Make them sweet by adding cacao nibs and plenty of dried fruit like cranberries, blueberries, and raisins, or opt for higher protein with peanut butter, coconut flakes, slivered almonds and pumpkin seeds. Buying the dried fruit, nuts and seeds at your nearest bulk store can make them more affordable.

Overnight Oats

Make this delicious and inexpensive snack in a mason jar and leave it in your fridge overnight. You can get creative with this one and add anything from cocoa to pumpkin puree to fresh fruit and peanut butter.

Homemade White Bean Dip

Make this dip in a big batch in advance and store it in sealed containers for up to three days. Serve with pita, sliced veggies or crackers.

Ants on a Log

Nope, it’s not just for kids. This one is a fun, easy meal for college students. Top celery stalks with peanut butter and raisins the good old fashioned way or experiment with other toppings.

If eating on campus is your only option, keep these tips in mind for eating well in a pinch…

Alp says there is one key area where college students often slip up. “Drinking your calories. If I could tell everyone to quit juice, I would,” she says.

Alp suggests avoiding soda or juice because these drinks can contain added sugar that can slow you down over the course of the day. Even so-called “sports drinks” can pack a lot of sugar into just one bottle.

And when you need an extra caffeine kick, consider avoiding energy drinks or sweet coffee drinks. Not only do these drinks cost a pretty penny, many pre-made coffee drinks have more sugar than a can of soda.

“If students choose water over juice, extra sugar in their coffee, energy drinks or pop they would be cutting quite a lot of calories out of their diet,” Alp says.

Because sometimes it’s impossible to avoid the food court when you’re stuck on campus all day, Alp has some guidance for choosing the healthiest option from fast food restaurants.

“Choose tomato-based sauces over cream sauces. Choose the grilled option over the fried option. And choose the whole wheat option whenever possible,” she says.

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Apache is functioning normally

December 7, 2023 by Brett Tams

Compliance, CRM, LOS, Servicing, Workflow, Internal Audit Products; Non-QM and Jumbo News

This website requires Javascrip to run properly.

Compliance, CRM, LOS, Servicing, Workflow, Internal Audit Products; Non-QM and Jumbo News

By:
Rob Chrisman

Tue, Dec 5 2023, 11:33 AM

My cat Myrtle doesn’t have a lot of rizz, and there are those that will argue that no cat has any charisma whatsoever. But plenty of marketing people do, or can create it, and even if you’re not in marketing, there are some clever marketing people out there. Creative minds as well, and if you’re looking for a Christmas present, here are the “best inventions of 2023” per Time Magazine. There is also cleverness and creativeness in the modular home manufacturing industry, probably far outpacing the ability of state and local government to issue permits. Meanwhile, lenders are facing a winter trying to figure out if they are in the “Survive until ‘25” camp or the “Grow more in ‘24” mindset? The credit industry is reeling as lenders grapple with soft versus hard pulls, renegotiating pricing, and bundled deals. And for some reason LO comp continues to be unsettled: dual comp, MLOs as real estate agents, transferring pipeline data when changing jobs, different fee structures within the same state, and so on. (Today’s podcast can be found here, and this week’s is sponsored by nCino, makers of the nCino Mortgage Suite for the modern mortgage lender. nCino Mortgage Suite’s three core products, nCino Mortgage, nCino Incentive Compensation, and nCino Mortgage Analytics, unite the people, systems, and stages of the mortgage process. Hear an interview with Mayer Brown LLP’s Holly Spencer Bunting on RESPA happenings and how the industry can get to better regulation.)

Lender and Broker Products, and Services

Out with the old; in with the new! One of the things we most look forward to in December (besides the holidays, of course!) is the opportunity to envision and plan for a great future. We’ve curated a killer panel of industry execs who will share best practices and their favorite secrets to help you usher in 2024 at the highest possible note. TrustEngine’s Dave Savage hosts Dustin Owen of Waterstone Mortgage and Brian Covey of Revolution Mortgage in “Chaos to Clarity”, a sure-to-be deliciously juicy webinar that will inspire and energize you to end 2023 with a bang and move powerfully into the new year. Register now to save your seat!

What’s an internal audit anyway and do you need one? An internal audit acts as a third line of defense for your mortgage operation. It provides comprehensive assurance based on the highest level of independence and objectivity to evaluate the effectiveness of management’s internal controls. This function should advise your mortgage operation on plans to achieve the company’s strategic, operational, financial and compliance goals. An effective internal audit should go far beyond just checking a compliance box; it should be an integral part of protecting your company. If you want to ensure you’re adhering to regulatory requirements and demonstrating good faith business practices, a Richey May internal audit is a good fit. If you’re looking to be Fannie Mae approved in the future or want to maintain your approved status, it’s required. If you’re unsure whether you need an internal audit, ask one of Richey May’s experts today or learn more here.

“Is it a challenge getting what was promised out of your current subservicer? New regulations are always moving the compliance goal posts and your customers are craving the newest technology and high-quality customer experience to meet their needs. After all, aren’t those the reasons you contracted with them? Perhaps it’s time for a change. Come meet Servbank at the MBA Servicing Solutions 2023 and let us show you how our cutting-edge, fully transparent and award-winning servicing platform (SIME), combined with our family of caring Customer Care reps, will protect your company from regulatory misses and keep your customers loyal by delivering a superior experience every time. If your current subservicer promised to make life easier for you, but continues to miss the mark, now is the time to partner with Servbank, the nation’s only fintech bank subservicer, who can meet your unique needs. Stop by booth #601, or schedule a meeting with Servbank.”

Right in time for the holidays, Floify has launched Floify Broker Edition, a one-stop lending platform that makes it easy for brokers to manage loans in one place. Wrapped in Floify’s famously sleek interface, Floify Broker Edition is packed with magical features that save precious time and money, such as automated mortgage call reporting, dual AUS functionality, and PPE and wholesaler integrations. Just like Santa’s elves, automated workflows advance loans behind the scenes so brokers can spend more time spreading the joy of homeownership and less time pushing paper. Treat yourself (and your borrowers!) this holiday season with a lending platform that’s a joy to use. Experience the magic of Floify Broker Edition firsthand and book a demo today.

Take advantage of more opportunities by adjusting your business to match the market. Recently, lenders who could quickly scale their home equity products were able to capitalize on the increased demand. Are you maximizing home equity lending in your system of record? Encompass® by ICE Mortgage Technology® is the only solution on the market that can be easily configured without any development efforts to support a user’s unique products and workflows for each of their channels, including retail, consumer direct, HELOC, wholesale and correspondent. This means you can quickly react to market changes and manage your business in your own way. Click here to read our recent blog that shares strategies to maximize your home equity lending business and how Encompass makes it easy.

A borrower’s servicing experience is only as good as the back-office environment that supports it, which is only as good as the technology that powers it. That’s why ICE is actively moving servicing forward through digitizing the consumer experience and streamlining back-office operations. The mortgage technology experts at ICE understand that effective servicing solutions are built from the “outside in”, designing with the customer in mind and working until the same level of convenience is brought to those working behind the scenes. Read the new blog from Sandra Madigan, Chief Digital Officer at ICE Mortgage Technology, to see how ICE is engineering with empathy, and helping people achieve and maintain the dream of homeownership.

In Naples, people hurl plates, appliances and even furniture out of their windows on New Year’s Eve to symbolize making room for the new. If your LOS has been causing you strife, take a cue from the Neapolitans and chuck it out the window. Dark Matter Technologies is here to help you usher in a more prosperous 2024 with its Empower LOS. A fully cloud-based system, Empower brings your tech ecosystem together in one place and intelligently orchestrates delightful borrower experiences and efficient loan production. Schedule a demo with the Dark Matter team to learn how Empower can elevate your business in the year ahead.

Two things come to mind when looking for strategies to help LOs today. First, understand home buyers in the context of uncertainty in the market today. Get back to basics of why homeownership still makes sense: pride of ownership, building equity for the future, and a better environment for their family to live and grow. Next, be able to articulate good solid strategies to make home buying more affordable, both down payment strategies and ARMs to lower payments. It’s also important to understand buyer’s bias against ARMs and counter with common sense arguments. Usherpa, the #1 ranked mortgage CRM in customer satisfaction and loyalty, is offering these FREE printable handouts with informational scripts to use when talking with your homebuyers and valuable resources you can easily send them about ARMs.

ActiveComply is thrilled to introduce a brand-new product, WebCompass™, to discover and manage your websites for branding, compliance, and accessibility. The same power as SocialShield™ for Social Media but now for website and brand compliance. With WebCompass™ you can discover and monitor company and employee websites & web pages, protect your brand with website content scans and compliance tracking, uncover rogue or unauthorized websites, and streamline reporting demands during regulatory examinations. Sign up today for a demo and the first 25 customers will receive a discount. ActiveComply cloud-based solutions help highly regulated industries confidently manage their social media and website compliance and virtual inspections.

Non-QM, DSCR, Jumbo Broker and Correspondent Program News

Can we continue our same ad please: Long-term Rental or Vacation Rental? Visio Lending is the nation’s leader in Non-QM Investor DSCR loans for buy and hold SFR rentals with nearly a decade of experience and over $2.5 billion in originations. No-DTI, 30-year terms, rate buy downs, free 45-day rate locks; I/O and Sub-1 DSCR options available. Through our top-notch Broker Program, brokers are able to earn up to 2 points YSP, and 5 points total. Visio Brokers can count on a designated Account Executive and in-house processing.

PRMG offers several Non-QM resources such as product matrices, job aids, trainings, calculators, worksheets, and other information to assist with using Non-QM loan products. Access the TPO Non-QM Resources page for detailed information.

Angel Oak Mortgage Solutions announced the release of its Blended Rate Calculator, providing borrowers with a quick and straightforward tool to estimate potential loan scenarios.

In tandem with its Angel Oak Mortgage Closed End Second Loans program, the Blended rate calculator helps you show borrowers what their 1st and 2nd payments, as well as LTV and blended rates, will be for both mortgages. This tool enables borrowers to easily assess how they can tap into their home’s equity while retaining their first mortgage.

PHH Mortgage announced new products for Non-Agency offering as of November 28th. Go to the company library to view the information.

A Jumbo option designed to empower homebuyers in high-value markets to secure their dream homes. Explore the advantages of Plaza’s new Jumbo Champion loan program, featuring top-notch pricing, loan amounts up to $3 million, and eligibility for FICO scores starting from 720.

LendSure Mortgage Corp., a Non-QM wholesale lender, announced the launch of its new Profit & Loss (P&L) Loan Program offering “a simplified and user-friendly process for business owners seeking capital in a complex financial landscape.” LendSure’s P&L Loan Program is designed to cater to business owners and self-employed investors with fluctuating seasonal income or cash businesses. It eliminates the need for a self-employment questionnaire, simplifying and speeding up the application process and making it more convenient for borrowers to secure financing. “We aim to empower business owners, redefining industry standards and facilitating their path to financial success… The program offers two tiers of loan amounts, giving borrowers the choice to provide only P&L statements for loan amounts up to $1,000,000 or supply two months of bank statements with P&L statements for loan amounts up to $1,500,000. This flexibility enhances the broker-customer relationship by providing a straightforward, efficient solution for business owners. Reach out to LendSure for more information.

First time home buyer/ first time investors now have a chance to buy an investment property with no income. Hometown Equity Mortgage offers a Bridge for First time home buyers; up to 75 percent LTV on a purchase, no ratio DSCR product, NO VOR/VOM, allowed to live rent free. FICO down to 650, Flexible guidelines, 12-24 month I/O with no prepay or EPO.

HighTech Lending Wholesale is now offering Jumbo Reverse Mortgages the Platinum Reverse which comes in three variations: Maximum LTV Fixed Rate, Adjustable Rate with a Line of Credit, and Reduced LTV with a lower Fixed Rate. The minimum age for the Platinum is 55 in most states, but some require the borrower to be 60 or 62.

Capital Markets

First Community Mortgage has named Jeff Pancer to the new position of Executive Vice President, Capital Markets. Congratulations!

Markets finally paused recent optimism that has been riding on the assumption that the Fed will lower interest rates in 2024. Until yesterday, that optimism had fueled rallies in both stocks and bonds over the past few weeks, with investors continuing to overlook Fed rhetoric and bet on deep interest rate cuts next year. Fed Chair Powell on Friday reiterated that it is too early to consider cutting rates, and that the Federal Open Market Committee plans to keep policy restrictive for some time. Despite his stance, markets are still at odds with the Fed, pricing in the first rate cut as early as March and 125 basis points of rate cuts in total for 2024. Remember, sticky inflation can prevent the Fed from cutting.

The Fed is widely expected to leave rates unchanged for the third consecutive FOMC meeting next week, in what would be no change for the fourth out of the past five meetings. However, the post-meeting statement will likely continue to indicate that additional tightening is possible. The fear is that the Fed declaring victory too early while the economy is growing, and the labor market is tight is a risk if inflation spikes back up. The Fed has entered its blackout period ahead of the meeting, so we won’t get any more chatter from FOMC members until after the meeting. Additionally, there will be no Treasury note or bond auctions this week. This week will be dominated by the jobs report on Friday where expectations are for an improvement from October’s report: an increase of 180,000 jobs in November and no change in unemployment.

Today’s economic calendar has a lot of non-market moving releases: Redbook same store sales for the week ending December 2, final November S&P Global services PMI, expected to decline slightly, ISM non-manufacturing PMI for November, expected to tick up, and JOLTS job opening for October, supposedly sliding to 9.35 million from 9.55 million in September. We begin the day with Agency MBS prices better by .125-.250, the 10-year yielding 4.23 after closing yesterday at 4.29 percent, and the 2-year yield down to 4.52 as investors continue to believe, perhaps mistakenly, that the Fed is not only done raising rates but will come around to cutting them.

Download our mobile app to get alerts for Rob Chrisman’s Commentary.

Source: mortgagenewsdaily.com

Apache is functioning normally

December 2, 2023 by Brett Tams

Here’s why you should call the Hoosier state home.

Indiana is celebrated for, among many other things, its agricultural prowess, its hardworking people and its top-tier higher education institutions. From the spanning farmlands to the rich culture, Indiana stands out in its own distinct way. But what is Indiana known for, exactly? It’s certainly not just cornfields and basketball: Let’s take a deeper dive into the intricacies and unique characteristics that make the Hoosier state such a great place to call home.

Employment

Historically known as a manufacturing hub, Indiana continues to play a pivotal role in the nation’s large-scale material production. The state hosts automotive giants, with companies like General Motors and Subaru operating major facilities. This industry not only provides jobs in production but also fuels ancillary industries, creating a ripple effect across the job market of the entire state.

The healthcare infrastructure in Indiana is robust, offering a ton of opportunities for professionals in a number of fields. Renowned medical institutions like Indiana University Health and the Mayo Clinic Care Network provide a spectrum of healthcare services and contribute significantly to the employment scene. From skilled medical practitioners to support staff, healthcare plays a vital role in the overall health of the statewide job market.

With renowned educational institutions like Purdue University and Indiana University, the state has a wealth of employment opportunities in academia and research. These institutions not only attract educators but also drive research and development initiatives, fostering innovation and intellectual growth.

Indiana’s business-friendly environment has nurtured a hard-working spirit. Startups and small businesses find ample support through various initiatives and incubation programs. This fosters a strong entrepreneurial ecosystem, contributing to widespread job creation and economic growth throughout the state.

Outside

Indiana is endowed with natural wonders that captivate outdoor enthusiasts. Indiana Dunes National Park, situated along the southern shore of Lake Michigan, boasts stunning sand dunes, pristine beaches and diverse ecosystems. The Hoosier National Forest, covering over 200,000 acres, is a haven for hiking, camping and wildlife observation to boot.

One of the most iconic attractions in Indiana is the Indianapolis Motor Speedway. Known as the Racing Capital of the World, it hosts the world-famous Indianapolis 500, the world’s largest single-day sporting event. Racing aficionados from around the globe flock to witness the thrilling spectacle of speed and skill.

Food

Indiana’s food scene reflects a rich amalgamation of flavors. The state is known for its Hoosier tenderloin sandwich — a delectable deep-fried pork or beef cutlet. For those with a sweet tooth, the Hoosier sugar cream pie is a local favorite, showcasing a delightful blend of sugar, cream and vanilla.

Five of the best restaurants in Indiana

With a thriving agricultural landscape, Indiana’s farm-to-table movement is strong thanks to the surrounding necessary resources. Farmers’ markets dot the state, offering fresh produce, artisanal cheeses and handmade crafts. These markets provide a glimpse into the heart of Indiana’s agricultural efficiency.

Culture

The Amish community has a strong presence in Indiana and contributes significantly to the state’s cultural diversity. Visitors can explore Amish country, characterized by simple living, traditional craftsmanship and horse-drawn buggies. Shipshewana, with its Amish-focused attractions and markets, is a window into this unique way of life.

Indiana has thriving artistic communities, like Bloomington and Nashville, where galleries, studios and theaters flourish. The Indiana University Art Museum in Bloomington showcases a diverse collection spanning centuries and traversing cultures. Brown County, often referred to as the “Art Colony of the Midwest,” attracts artists and amateur critics alike.

Entertainment

Indiana has left an indelible mark on the world of music. The legendary King of Pop, Michael Jackson, hailed from Gary, while the “Piano Man” Billy Joel was born in the state capital, Indianapolis. The Indianapolis Symphony Orchestra, known for its dynamic performances, adds a symphonic note to the state’s cultural landscape.

Throughout the year, Indiana hosts its fair share of festivals and fairs celebrating everything from food to arts. The Indiana State Fair, one of the oldest state fairs in the U.S., is a melting pot of experiences, with concerts and carnival fun for all.

It’s all about Indiana

With its unique blend of natural wonders, culinary delights, cultural richness and quality entertainment, Indiana invites exploration beyond the ordinary. This state, often overshadowed by its larger neighbors, stands as a testament to the richness and diversity that can be found in the heartland of America.

Ready to find your ideal Indiana apartment? You’ve come to the right place.

Source: rent.com

Apache is functioning normally

December 2, 2023 by Brett Tams

JACKSON, MI – Since it began six years ago, Jackson nonprofit SOAR Café and Farms has strived to heal and house women who experienced trafficking, incarceration, addiction or abuse.

SOAR, which stands for “She Overcomes And Rises,” will look to fulfill that mission in a new home, with plans to transform the former Anna’s Gifts & Décor building, 401 N. Mechanic St., into a cafe, CEO and Founder Michelle Cochran said.

“It’s going to be a mentoring cafe because we’re going to be coaching ladies through employment of the cafe, and helping them gain more freedom and get back to sustainability,” Cochran said.

SOAR has operated out of the former Woman’s City club building at 300 S. Brown St., to house some women in need of services since 2019. Moving into a new facility will allow SOAR to support these women in other ways, such as employment and mentorship.

Related: Historic Jackson house renovated for women who have survived abuse

Anna’s Gifts & Décor, which closed at the beginning of 2023, offered a small cafe in the front of the store called Anna’s Porch Café, which shut down in 2021.

The building was purchased by Cornerstone Properties of Mid-Michigan’s owner Mary Garcia, who is also a SOAR board member. Garcia purchased the building with the intent to lease the facility to the nonprofit, she said.

“SOAR is a passion project for me,” Garcia said. “I’ve seen the success of the program, and if I can make a small contribution to continue that and expand that beyond just the residential program, it was always Michelle and mine’s vision.”

Related: ‘Nobody responded.’ Unanswered job listing forces Anna’s Porch Café to close after 23 years

Residents of SOAR, or even women in the community living with similar circumstances, will be able improve their work skills, make connections with the community and build their resumes by operating the cafe.

Eventually, it is the hope of Cochran to see the women outgrow it and move into the workforce.

“They (can) work there as long as they need or want to,” Cochran said. “When they are done getting the skills and education they need there, they move on to bigger and greater things and more ladies come and take their place.”

Once open, SOAR would like to serve a farm-to-table style menu with breakfast and lunch options. They are also hoping to incorporate a few items from the former Anna’s Porch Café’s menu, she said.

SOAR will also offer closed off sections for groups and meetings, a grab-and-go section, some retail space and some membership cubicles in the 10,000 square foot facility, Cochran said.

Proceeds from the cafe will go toward continuing to run Soar’s programs and the cafe, Cochran said.

Some renovations need to take place before this dream comes true. The cafe portion of the building will be relocated to the center of the store, and the porch will be transformed into cubical spaces.

The nonprofit is fundraising to purchase furniture, equipment and appliances with a goal of $90,000. People can donate to this effort through the SOAR website.

Construction will likely start in January, with a targeted completion of May of 2024, Garcia said.

Cochran is looking forward to offering a cafe inside of this location again, as well as offering women the place to grow and learn skills, she said.

“We’re excited about serving the community and serving the women we serve,” she said.

More information and updates can be found on SOAR’s Facebook page.

Want more Jackson-area news? Bookmark the local Jackson news page or sign up for the free “3@3 Jackson” daily newsletter.

Source: mlive.com

Apache is functioning normally

December 1, 2023 by Brett Tams

Every family has their own reasons for choosing the type of Christmas tree that graces their home each December, but for me, nothing equals the smell of a live tree. Once a live tree is in the home, the unmistakable smell of pine, spruce or fir envelopes the room and our olfactory senses trigger fond memories of family Christmases from years ago.

Christmas tree growers would tell you that there are other reasons to choose a live Christmas tree over an artificial one, including the fact that live trees are more environmentally friendly. Christmas trees are planted specifically for harvest and subsequent replanting and an acre of Christmas trees produces enough oxygen to support 18 people each day, according to Ohio State University Extension research. Each Christmas tree will remove up to one ton of carbon dioxide from the atmosphere during its lifetime. And live Christmas trees can be recycled through chipping or composting.

Choosing a live tree

You can be assured of getting a fresh tree if you cut your own tree from a local Christmas tree farm. While this is a cherished family tradition for many, the convenience of purchasing a pre-cut tree is more desirable for others.

To check a pre-cut tree for freshness, look for flexible needles that remain firmly attached when you tug on them. All needled evergreens shed their oldest needles each year, so there is no need for concern when brown needles fall from the interior of the tree when you knock the base of the tree on the ground. Just be sure that these brown needles are thoroughly shaken off the tree before taking it indoors. If the outermost green needles pull out easily, or if they appear a dull, lifeless green, the tree may be past its prime.

Maintaining freshness and aroma

Plan to place your live tree in a stand with a basin that holds at least a gallon of water. A cut tree will absorb a surprising amount of water, particularly during the first week it is placed indoors, so replenish water daily. Avoid whittling down the sides of the trunk of the tree to fit into a stand. The outer layers of wood are the most efficient in taking up water and should not be removed. If the tree is to be stored for more than a couple of days before it is set up indoors, its trunk should be placed in water and it should be stored in a cool, shaded, and protected area such as an unheated garage.

5 tips for maintaining healthy houseplants during winter months

If the tree has been cut within 12 hours of set up indoors, it will not be necessary to recut the trunk. If it has been longer than 12 hours since harvest, the trunk should be re-cut to improve water uptake. Cut a ¼-inch-thick slice from the base of the trunk and be sure to make the cut perpendicular to the stem axis. Don’t cut the trunk at an angle or into a v-shape, as this will make it difficult to hold the tree in the stand and reduce the amount of water the tree will uptake.

How to plant paperwhites for the holiday season

Just in case the ground freezes before you have a chance to plant your living tree outdoors in January, its best to dig the planting hole now where you wish to plant the tree. Be sure to dig the planting hole two or three times wider than the container or root ball of the tree you plan to purchase. The hole should be dug to the same depth as the as the container or root ball. Soil dug from the hole can be stored in the garage in a wheelbarrow or in large containers to avoid freezing.

Mike Hogan is Extension Educator for Agriculture and Natural Resources and associate professor with Ohio State University Extension. [email protected]

Source: dispatch.com

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Healthy Granola Cookies

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If eating on campus is your only option, keep these tips in mind for eating well in a pinch…

Compliance, CRM, LOS, Servicing, Workflow, Internal Audit Products; Non-QM and Jumbo News

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Here’s why you should call the Hoosier state home.

Employment

Outside

Food

Five of the best restaurants in Indiana

Culture

Entertainment

It’s all about Indiana

Choosing a live tree

Maintaining freshness and aroma