OpenClose has announced that is has implemented the functionality necessary for lenders to adhere to the Consumer Financial Protection Bureau’s (CFPB) new Qualified Mortgage (QM) and Ability-to-Replay (ATR) rules. The company’s client base is successfully processing QM loans.
OpenClose began adding numerous lines of code to its LOS well in advance of the CFPB’s QM deadline of Jan. 10, 2014. While at the point-of-sale, the loan officer takes the 1003 application, selects a product, and clicks a QM button that returns a decision if it’s a QM or non-QM loan. If it meets QM guidelines, an evaluation report and ATR certification are provided for the lenders’ records.
Once the loan has been decisioned, it seamlessly moves through OpenClose’s LOS workflow where the loan is continuously checked in the background on a screen-by-screen basis for any changes that affect QM requirements. If a change is detected, an alert appears on the screen that the user is working on, which provides a pass/fail indicator along with messaging as to why there was a QM fail so the user can address it and proceed.
Custom business rules can be configured within the LOS to meet lenders' specific workflow preferences and easily implement any new rules the CFPB introduces. As a result, lenders are able to turn on a dime and remain QM compliant given changes to guidelines or the introduction of new rules.
“A lot of technology vendors are just jumping on the band wagon and touting QM readiness,” said Rob Pommier, SVP of business development and strategic alliances at OpenClose. “But there are lots of changes to LOS code bases that vendors must design, implement and test before being rolled out into a production environment. That’s no easy task. It took us many months of development and making alterations to our graphical user interface (GUI) in order to ensure that our end-to-end system is what I term ‘bulletproof QM ready.’”
“The work that OpenClose has done to their LOS to meet QM rules has made our jobs incredibly easy,” said OpenClose client Colleen Thingelstad, director of real estate lending at Horizon Credit Union. “We don’t need to think; the system automatically does everything for us. It has literally saved us countless hours of work, and our investors are very comfortable with accepting the system’s finding s.”
OpenClose hasprovided a number of different training activities in order to effectively prepare its clients to utilize the added QM functionality to its LOS. This was accomplished using individual hands-on training, webinars and detailed supporting documentation. All of the company’s clients are fully ready to accept, process and deliver QM loans to investors, in full accordance with CFPB rules and underwriting guidelines.