PNP SPECIFICATIONS PNP Name/ History Procedure: Tracking Brokered Out s Date Issued: 04/01/2014 Date Effective: 04/01/2014 Date Revised: 07/12/2018 Production Channels Retail Correspondent Wholesale Accountable Personnel/ Department s Branch Relations Coordinators Branch Account Managers Issuing Personnel/ Department Subject Matter Expert (SME) Purpose Executive Vice President, Operations Director of Processing Branch Account Managers The purpose of this procedure is to ensure that each Brokered Out loan is handled in a manner that meets AFN, lender and investor guidelines and standards, and is properly handled for HMDA purposes. RELATED DOCUMENTATION Guide Matrix Form Training Procedure Branch Processing Manual AFN Approved Lenders for Brokering Out s Brokered Out Check Cover Sheet Encompass Newsflash #131: How to Duplicate a Canceling s Denying s Policy Compliance with ECOA/Regulation B
RELATED DEFINITIONS Brokered Out When a loan is originated by an AFN Mortgage Originator, and the loan is for a niche product not offered by AFN or its investors, the loan may be originated and then submitted to a lender that will fund the product. When this occurs, AFN refers to it as Brokering Out or a Brokered Out loan. s may be brokered out if AFN does not offer the product, if the brokering out is first approved by Executive Management, and if the broker/lender appears on the AFN Approved Lenders for Brokering Out s matrix. Table of Contents Changing the File Channel... 1 Submitting a File for Broker Out Approval... 2 Completing Milestones... 4 Checking Pipeline View for Brokered Out s... 6 Tracking Brokered Out s... 7 Moving Tracked s to the Closed Folder... 8
REVISED 07/12/2018; PAGE 1 OF 8 Changing the File Channel 1. Go to the AFN - Borrower Origination Summary and change the Channel field to read Brokered and then click the [Save] button. 2. If Encompass does not automatically change the milestones after the Save in Step 1, Complete Step 2 (otherwise, proceed to Step 3). a. Click the menu header at the top of the page; select the Manage Milestone Templates option, and then click the Apply Automatic Mode option. b. The following message will appear; click the [OK] button to proceed, and then click the [Save] button. c. The Milestone Log Change dialog box will appear, displaying the Current (Default) milestones, and the New (Brokered Out) milestones; click the [OK] button to accept the changes and then click [OK] to confirm.
REVISED 07/12/2018; PAGE 2 OF 8 Submitting a File for Broker Out Approval Notes: The AFN must ensure compliance with AFN s policies and procedures for Brokered Out loans. All Brokered Out loans must have corporate approval to broker out prior to sending the package to the lender for consideration. For HMDA compliance purposes, if a loan cannot be done inhouse, the loan must be denied in Underwriting, and the Originator must open a new loan for brokering out. (See Denying s procedure and Compliance with ECOA/Regulation B policy for more information.) The Corporate office will conduct a file audit to ensure file data and documentation are complete. must respond in a timely manner to any/all requests for additional items needed. Failure to complete all items and upload required documentation to the file may result in delay of payment to the Branch for the closed loan. Brokered Out loans must comply with Regulation B: o Notice of Incomplete Application (NOIA) requirements and deadlines for issuing an approval or adverse action apply. AFN must follow Reg B rules regardless of who issued disclosures. AFN must issue NOIA within 30 days of application date; this will extend time to approve or deny to 60 days if: - Lender does not approve or deny by day 30, or - Brokered out loan not submitted to Lender by day 30. o AFN must cancel loan, and may originate new loan for the borrower (if necessary), if: NOIA not sent timely & loan not submitted to lender, or NOIA sent timely, but loan not submitted to lender by day 60. If all other timeline requirements met and loan submitted to lender with sufficient information for making a credit decision prior to day 60, AFN is not responsible for issuing a decision (approval or denial). For more information, see AFN procedure for Reg B - Handling Incomplete Files.
REVISED 07/12/2018; PAGE 3 OF 8 Submitting a File for Broker Out Approval (Continued) 3. Go to the Encompass Brokered Out form (screen) and complete the following sections/fields: Complete the Info section all fields are required, including the lender selection. Complete the Brokering Info section all fields are required. o When Date field is completed, Encompass will populate your name in the field. If loan is a HELOC using loan program HELOC30, proceed to Step 5. below (Corporate approval is not required). Save and exit the file. o This will flag the loan to appear in the Branch Account Managers Broker Out pipeline view. A Branch Account Manager (BAM) will ensure the Corporate Approval section is completed upon review (typically within 24 hours of the request).
REVISED 07/12/2018; PAGE 4 OF 8 Submitting a File for Broker Out Approval (Continued) 4. Wait until Corporate Approval is received to submit the loan to the lender. An alert will fire in Encompass if the loan is placed in the Brokered channel without Corporate approval to broker the loan. Approval may take up to 24 hours, so please plan accordingly. For government loans, approval must be reviewed by AFN Executive Management to determine if there is an acceptable reason why the loan should be brokered out and cannot close in-house. An email notification will be sent through Encompass upon exception request review. Completing Milestones 5. Milestones for Brokered Out loans appear as follows: Started (automatically completed when loan is originated) App Received ( Officer to complete when signed disclosures are returned) Processing Submit to Lender Approved by Lender Lender Docs Out Lender Funded Completion (automatically completed when final review is signed off by a Branch Account Manager) 6. Upon review of the file as submitted by the Officer, if the submission is complete and compliant, complete the Send to Processing milestone.
REVISED 07/12/2018; PAGE 5 OF 8 Completing Milestones (Continued) 7. Ensure the file is complete and submit it to the Lender for Underwriting; complete the Submit to Lender milestone. 8. Upon receipt of an approval from the Lender, complete the Approved by Lender milestone. 9. Upon receipt of notification from the Lender that loan docs are out for signatures, complete the Lender Docs Out milestone. 10. After funding with the brokered out lender is confirmed, complete the Closing section of the Brokered Out screen in Encompass: a. Enter the funded date and the anticipated broker check information (the Lender Funded milestone will be automatically completed) 11. Upon receipt of the final Closing Disclosure and broker check: a. Ensure a copy of the documents is filed in the efolder. b. Ensure the Lender Funded milestone is complete and the funded date matches the funding date on the Closing Disclosure. c. Forward the Closing Disclosure and broker check to the corporate office, Attn: Accounting (see Brokered Out Check Cover Sheet). d. Corporate personnel will record the date the brokered out check was received, and the date received by Corporate. 12. Ensure a complete file is uploaded to the efolder, split into the appropriate document placeholders, including: All documentation submitted by the borrower(s) Signed 1003 (within 24 hours of receipt) Signed disclosures (within 24 hours of receipt) Credit report Lender s Initial Approval (Continued)
REVISED 07/12/2018; PAGE 6 OF 8 Completing Milestones (Continued) 12. (Cont d) documentation submitted to the Lender Lender s Final Approval (Clear to Close) All other required file documentation (as listed on the Encompass Brokered Out form [screen]) Note: The is responsible for ensuring compliance with AFN s policies and procedures for Brokered Out loans. The Corporate office will conduct a file audit to ensure file data and documentation are complete. The must respond in a timely manner to any/all requests for additional items needed. Failure to complete all items and upload required documentation to the file may result in delay of payment to the Branch for the closed loan. Checking Pipeline View for Brokered Out s Branch Account Manager 13. At least once daily, access the Encompass pipeline view labeled, BAM Brokered Out - Approval Pending to view loans that are pending approval to be brokered out. a. Review for Brokered Out Approval within 24 hours. 14. At least once daily, access the Encompass pipeline view labeled, BAM - Brokered Out - File Review to view loans that were brokered out, have funded, and require either initial BAM review or follow-up. a. Click the Reviewed Date column to sort loans by date; loans with no date in the Reviewed Date column have not yet been reviewed. b. Follow Steps 15-16 below for each loan to be reviewed, and then for each loan that requires follow-up. c. Monitor the pipeline view to ensure loans clear the Completion milestone within 10 days of the Funded date.
REVISED 07/12/2018; PAGE 7 OF 8 Tracking Brokered Out s Branch Account Manager 15. Go to the Encompass Brokered Out form (screen) and do the following: a. Under Info, ensure Lender, Amount, Program are correct. b. Under Closing, ensure the Funding Date is correct. c. Complete the Checklist section as follows: 1) Under Check Received By Corporate enter the Amount of check and Date it was received. 2) Ensure each item under Documents Required is in the efolder. a) If an item is in the efolder, click the Received checkbox next to the item; b) If an item is not in the efolder, type need in the Notes field next to the item. 3) Under Reviewed enter the Date the checklist review was completed and the Auditor field will populate with your name. d. Email the a request for missing items: 1) Return to the Brokered Out form Checklist section and enter the Received date as items are received from the. 2) Upload items to the efolder (or ensure the has uploaded and filed them properly) as they are received. e. When the file is complete, and all needed items are filed in the efolder, scroll to the bottom of the Encompass Brokered Out form to see the All required Documents have been received sign-off section: 1) Complete the Date field and the Auditor field will populate with your name. f. Encompass will auto-complete the Completion milestone.
REVISED 07/12/2018; PAGE 8 OF 8 Moving Tracked s to the Closed Folder Branch Account Manager 16. At least once weekly, access the Encompass pipeline view labeled, BAM - Brok. Out Move to Closed to view loans that were brokered out, have funded, and have been tracked and signed off by your department. a. Single-click to select one loan on the pipeline view, and then press [Ctrl] + [A] to select all, OR single-click the first loan in a range of loans, then press the [Shift] key and single-click the last loan in the range (then release the [Shift] key). b. Right-click on any selected loan to see an action menu. c. Select the Move to Folder option and then select Closed.