[Bruce]

Subject: Fannie Mae and Freddie Mac now fully approve VantageScore 4.0—what lenders need to know

In a nutshell, the FHFA has instructed Fannie Mae and Freddie Mac to accept VantageScore 4.0 from all mortgage originators effective right away. This is not a change that will take place in the future—it is happening at this moment, and it makes it possible in a fundamental way to qualify borrowers who have previously been ‘credit invisible’ or have been penalized by the traditional FICO models.

What Just Happened

In July 2025, FHFA Director Pulte announced that VantageScore 4.0 would be put into immediate use for all mortgages guaranteed by Fannie Mae and Freddie Mac. Although the first instruction had allowed the industry until the fourth quarter of 2025 to make the switch, the new directive speeds up the process—thus lenders are (and should) begin using VantageScore 4.0 today.

Fannie Mae has already updated its Single-Family MBS disclosure files to include VantageScore 4.0 data, and the two GSEs are now accepting these scores from all lenders who originate loans.

Why This Matters for Your Pipeline

1. Thirty-three million additional borrowers who can be scored

VantageScore 4.0 can assign a score to about 33 million consumers who could not previously be scored using traditional models. These consumers include those with thin credit files, recent immigrants, and younger people who are building up their credit. For lenders who are dealing with first-time homebuyers or people with poor credit, this represents a major advantage.

2. Trends in the data make a difference

VantageScore 4.0 differs from classic FICO (which relies on a static snapshot) in that it looks at data over a period of 24 months that has been trended.

• Shows payment trajectory, not just current balance
• Gives rewards to people who are paying off their debt rather than those who are keeping high balances.
• Captures credit behavior direction—critical for post-pandemic credit recovery

Collection of payments for medical bills is no longer punished.

While classic FICO scores include paid medical collections when calculating the score, VantageScore 4.0 does not; this fact alone can make the difference between a borrower’s application being approved or denied if they have settled old medical debt.

4. Alternative Data Integration

The model uses rental history, payments for utilities, and telecom data where they are available—this is very beneficial for borrowers who have limited traditional credit.

Performance Validation

An independent analysis of 20 million mortgages found that VantageScore 4.0:

• Predicted 49% more pandemic-era defaults than Classic FICO (superior risk identification)
• Delivered a 20% lift in originations without adding incremental risk
• Correctly identified higher-risk loans when FICO scores were inflated

Operational Considerations

For Lenders:

• Ask your loan originator and your credit report provider—most of them have already incorporated VantageScore 4.0
• Update your adverse action notices and disclosures
• Train the LOs to decide when to use the VantageScore rather than the FICO (or both).
• Review investor overlays—some may still require FICO during transition

For Borrowers:

• Consumers with 620-660 FICO scores may see significant score differences
• People who are restoring their credit following a difficult period usually obtain a higher score on the VantageScore 4.0.
• Trended data rewards consistent payment behavior over time

My Take

It’s not merely a ‘new scoring option’ but rather a strategic move in the direction of more inclusive and predictive underwriting. For originators at Gustan Cho Associates and other firms dealing with non-QM and credit-challenged borrowers, VantageScore 4.0 provides them with another tool allowing them to say ‘yes’ when the traditional models would say ‘no’.

The companies that make the quickest adaptation will gain market share in the 33-million-person ‘credit invisible’ segment. The issue isn’t whether or not to adopt it—rather, it’s about how swiftly you can put it into operation.

Questions for the Forum:

1. Has anybody begun to get both the VantageScore 4.0 and FICO? Is there a noticeable difference in the scores?
2. Which LOS integrations are working well, and which ones are causing problems?
3. Are investors currently accepting VantageScore 4.0 without the use of overlays, or are FICO requirements still in effect behind the scenes?

Please share your experiences from the field—let’s gather together the realities of implementation.

This article is provided for informational purposes and should not be regarded as legal or compliance advice. It is essential that you check the latest GSE and investor guidelines before making any changes to your credit-pulling procedures.

Want me to adjust the tone (more technical, more conversational) or add specific sections on compliance, pricing adjustments, or investor considerations?

• This reply was modified 5 days, 22 hours ago by  Bruce.

[Bruce]

I’m very sorry for your loss. I understand your parents’ home means much more to you than just its financial worth. Let me start by clearing up an important point:

Your Chapter 13 bankruptcy discharge in July 2025 alone will not automatically cause your loan application to be denied. Based on what you’ve shared, we’ll need to review your situation carefully before we can determine whether you qualify. There may be several options, like FHA manual underwriting. Depending on your situation and the property, VA, USDA, or Non-QM loans could also work.

Your Chapter 13 Discharge Does Not Automatically Prevent FHA Financing

Some of the information you got might have left out important details. Fannie Mae conventional financing generally requires a two-year waiting period after the discharge of a Chapter 13 bankruptcy. Fannie Mae specifically does not provide an extenuating-circumstances exception that shortens the two-year waiting period following a Chapter 13 discharge. Freddie Mac also generally uses a 24-month recovery period following a Chapter 13 discharge.

If a lender follows only conventional guidelines, you may need to wait until about July 2027 after your July 2025 discharge. But you may not have to wait until July 2027 for every mortgage option.

FHA treats Chapter 13 bankruptcy differently. If at least 12 months have passed since your payments started, you are not automatically disqualified. FHA also asks lenders to check your recent payment history, bankruptcy records, credit report, and whether the problems that caused the bankruptcy could recur. Because rules can vary, borrowers often get different answers from different mortgage companies.

Some lenders add extra requirements, even if FHA rules are flexible. That’s why it’s often best to start with FHA manual underwriting.

Based on what you’ve told me, I suggest starting with an evaluation.

An FHA Manual Underwriting Review Could be a Good Fit:

• The complete Chapter 13 repayment history
• Whether all required trustee payments were made as agreed
• The July 2025 bankruptcy discharge
• Your housing payment history
• Your credit history since the bankruptcy
• Your current credit scores
• Current employment and qualifying income
• Current monthly debts
• Available assets and reserves
• Any late payments, collections, charge-offs, or other derogatory credit following the bankruptcy
• The circumstances that originally caused the Chapter 13
• Whether those circumstances have been resolved and are unlikely to recur

Manual underwriting looks at your whole financial picture, not just your credit score. I would review all the important documents, not only the bankruptcy discharge date. You’ve faced some big challenges, so it’s important to document your situation carefully. The home suffered a major flood in July 2024. You and your father were displaced. There were insurance delays. You personally advanced money for materials and labor. You were paying temporary housing expenses while attempting to restore your parents’ home. Your father subsequently passed away in January 2026. These are major life events. Still, there’s one key thing to keep in mind during the loan review. The events you mention to explain your Chapter 13 bankruptcy need to match the actual bankruptcy timeline. For example, if you filed Chapter 13 before the July 2024 flood, the flood couldn’t have caused the bankruptcy. But these events can help explain later financial problems, loss of savings, or credit issues during or after bankruptcy. It’s important to make a clear timeline of what happened and your current situation. Documents usually support your case better than a long written explanation.

There is another matter that requires immediate attention: the reverse mortgage. She passed away in January. If he were the last borrower on the reverse mortgage and there is no eligible spouse or other qualified borrower, the reverse mortgage might already need to be paid off.

If this is an FHA-insured Home Equity Conversion Mortgage, or HECM, heirs who want to keep the property generally need to satisfy the reverse mortgage. Since you estimate the reverse-mortgage payoff at about $252,000 and the property is worth around $475,000, the reverse mortgage is significantly less than the home’s value.

In this situation, the estate or heir usually needs to pay off the reverse mortgage to keep the home. The HECM rule about paying 95% of the appraised value usually only applies if the reverse mortgage balance is higher than the home’s value.

Based on your numbers, there seems to be about $223,000 in value remaining after paying off debts, fees, and other costs, before selling expenses are deducted.

Since the home is worth a lot, it’s wise to look closely at all your options.ease Contact the Reverse-Mortgage Servicer Immediately

I strongly suggest you take care of this right away.

Please Contact the Servicer and Ask for:Current Written Payoff Statement

• A copy of the Due and Payable Notice
• The date the loan was officially placed into due-and-payable status
• The current deadline for satisfying the reverse mortgage
• Whether an extension has already been granted
• Whether another extension is available
• Whether the servicer has completed an appraisal
• A copy of any appraisal completed by the servicer
• Whether foreclosure proceedings have been initiated
• The date of any scheduled foreclosure action, if applicable
• The exact documentation they need showing that you are attempting to obtain financing

Federal rules give heirs a few options, like selling the home, paying off the reverse mortgage, or handling the debt in other ways. You might be able to get an extension during the sale or financing, but don’t count on it. Since your father passed in January, this is a top priority. The next step is to find out who owns the home now. Before you buy or refinance, make sure the title is clear.

• Is the property still titled in your father’s name?
• Was the property held in a trust?
• Is there a will?
• Has probate been opened?
• Has an executor or personal representative been appointed?
• Are you the sole heir?
• Are there other children or beneficiaries?
• Has the title already been transferred to you?
• Does the estate intend to sell the property to you? Depending on these factors, the transaction could proceed in one of two ways.

Purchase From the Estate

The estate could potentially sell the property to you, with the proceeds being used to satisfy the reverse mortgage.

Another way is to transfer ownership to you through inheritance, then get financing to pay off the reverse mortgage. The best approach depends on the title, probate documents, state law, loan program, and lender rules. Don’t assume anything about these details. The lender, title company, and possibly a probate or estate attorney should all work together before you finish the deal.

FHA Identity-of-Interest Rules Also Need to Be Reviewed

If the transaction is structured as a purchase from a family member or family estate, FHA’s identity-of-interest requirements need to be reviewed as part of the file.

FHA usually limits some family purchases to an 85% loan-to-value ratio, but there are exceptions for certain family sales of a main home. How the estate and title are set up is very important. With a $252,000 payoff and a $475,000 property value, you may still have some flexibility, even if loan-to-value limits apply.

VA or USDA Could Also Be Considered

If you are an eligible Veteran, active-duty service member, or otherwise qualify for VA financing, I recommend exploring the VA loan option as well. VA rules offer options for borrowers who have finished a Chapter 13 plan and may also help those still in Chapter 13 with steady payments. USDA loans might be available if the property is in a qualifying rural area and your household income meets USDA limits.

USDA rules say that if a Chapter 13 plan was finished 12 months or more ago, no special credit exception is needed for manual reviews or GUS Refer files just because of the Chapter 13 timing. Your July 2025 discharge is now more than 12 months old. We still need to check if the property and your household meet USDA eligibility rules.

Non-QM Loans are Better as a Backup Option, Not Your First Choice

Non-QM financing may also be available for borrowers with recent bankruptcies. Depending on the program, Non-QM lenders may require a shorter wait period after bankruptcy than conventional lenders do.

These Loans Can Have:

• Higher interest rates
• Higher down-payment or equity requirements
• Different reserve requirements
• Different income documentation
• Prepayment penalties in some investment-property programs
• Additional lender-specific restrictions

Since your home is worth a lot, Non-QM financing could be a backup. But I don’t recommend going for a more expensive Non-QM mortgage until we’ve checked if you qualify for FHA, VA, USDA, or other agency loans.

If this were my file, I would begin by gathering the following documents:

Reverse Mortgage and Property

• Current reverse-mortgage payoff
• Due-and-payable letter
• All recent correspondence from the reverse-mortgage servicer
• Servicer appraisal, if one has been completed
• Current deed
• Property tax bill
• Homeowners insurance
• Any existing appraisal
• Death certificates for your parents

Estate and Title

• Will or trust documents
• Probate documents
• Letters of administration or personal representative documents
• Documentation showing all heirs or beneficiaries
• Any proposed purchase agreement
• Are any documents already transferring ownership?

Chapter 13

• Bankruptcy petition
• Bankruptcy schedules
• Chapter 13 repayment plan
• Trustee payment history
• Bankruptcy discharge
• Any modifications to the repayment plan

Income and Employment

• Most recent pay stubs
• W-2s
• Two years of tax returns, if required, based on your income type.
• Employment history
• Other qualifying income documentation

Assets

• Bank statements
• Retirement or investment statements, if applicable
• Documentation of funds available for closing and reserves

Extenuating CircumstancesI Would Also Save Everything Related to the Events You Described:

• Flood insurance claim
• Insurance settlement documentation
• Contractor invoices
• Building-material receipts
• Proof of payments you personally made
• Temporary housing lease
• Rental payment history
• Correspondence concerning insurance delays
• Reconstruction timeline
• Retain any additioKeep any other documents that show extra costs.
• Keeping good records will help the loan reviewer understand your situation.
• Based on what you’ve shared, I think this is worth pursuing.his is worth pursuing.

I can’t confirm approval just from a forum post. We’ll need to fully review your income, debts, credit, bankruptcy records, property, estate documents, and reverse mortgage status before making a decision. Still, your Chapter 13 discharge in July 2025 doesn’t automatically disqualify you. That rule is too broad and only applies to some conventional loans, not all mortgage programs.

The First Things I Would Investigate Are:

1. The immediate status and deadline of the reverse mortgage.
2. How the title to the property is currently held.
3. Whether the transaction should be structured as a purchase from the estate or another form of financing after inheritance.
4. Your complete Chapter 13 trustee payment and discharge history.
5. Whether your current credit, income, debts, housing history, and reserves support the FHA manual underwriting.
6. VA or USDA eligibility, if applicable.
7. Non-QM financing if the agency options do not work.
8. You’ve already made great progress by keeping thorough records.
9. Don’t let feedback from other lenders discourage you.
10. Sometimes the answer really is no.
11. Sometimes the issue is that the lender or loan officer does not offer the specific program or manual underwriting option you need.
12. Your situation deserves a careful and complete review before you make any decisions.

Because of the reverse mortgage, I suggest making this review a top priority. There could be a real way for you to keep your parents’ home, and your situation deserves careful attention. My goal is to give you realistic hope, explain the differences between conventional and FHA rules, and emphasize the importance of the January 2026 reverse mortgage deadline.

[Bruce]

Mortgage Net Branch P&L Model: What MLOs Should Consider Prior to Joining a Mortgage Company

Discover operational details of the Mortgage Net Branch P&L Model, MLO compensation, costs of branch pricing, overhead, marketing, recruitment “offers,” and branch profitability.

An Overview of the Mortgage Net Branch P&L Model

The Mortgage Net Branch P&L Model provides experienced Mortgage Loan Originators (MLOs) with increased autonomy over business operations, compensation, staffing, and growth. However, higher compensation is accompanied by significant trade-offs.

Expenses such as branch costs, corporate fees, pricing, technology, payroll, compliance, marketing, and mortgage processing can substantially reduce the attractiveness of a compensation offer.

Therefore, before joining a mortgage company, MLOs should thoroughly evaluate the entire business model instead of focusing exclusively on commission rates.

Understanding the Competitive Nature of the Mortgage Industry

The mortgage industry has always been highly competitive. To succeed as a full-time, NMLS-licensed Mortgage Loan Originator (MLO), one must possess more than just technical expertise in loan structuring and closing. Securing borrowers is essential.

Without borrowers, there are no applications, no closings, and ultimately, no income. While this may seem obvious, it is one of the most important lessons I have learned in my career.

Since 2015, I have owned and managed an independent mortgage net branch. My experience demonstrates that loan origination is only one component of the business.

An MLO Must Also Consider:

• Lead gen
• Referral partners
• Marketing
• Loan ops
• Business ops
• Compliance
• Tech
• Payroll
• Licensing
• Staff
• Third-party vendors
• Office expenses
• Borrower retention
• DB management
• Reputation
• Recruiting
• Profit

An individual mortgage loan originator typically focuses on originating sufficient loans to sustain their income. In contrast, a mortgage net branch operator must manage all aspects of the business before, during, and after loan officer compensation.

This role presents a fundamentally different set of challenges.

Running a Mortgage Net Branch is Running a Business

Many seasoned loan officers mistakenly believe that becoming a branch manager automatically leads to a significantly higher income.

• This assumption is incorrect.
• A mortgage net branch operates as a business.
• Depending on the company’s structure and branch agreement, expenses may include salaries, payroll taxes, processing support, loan-origination systems, credit-report charges, technology, rent, office equipment, licensing, compliance-related costs, marketing, lead generation, insurance, accounting, administrative support, and numerous other expenses.
• Some expenses are covered by the corporate mortgage company, while others are charged to the branch or reflected in its profit-and-loss statement.
• The exact structure varies considerably from company to company.
• Therefore, MLOs evaluating a mortgage net branch opportunity should review the full profit-and-loss statement to accurately compare compensation structures.
• A higher gross compensation percentage does not always indicate a more profitable platform.

Marketing Is the Lifeline of a Mortgage Branch

Having the best processors, technology, loan programs, underwriting, and even experienced loan officers can set a branch apart from the competition. A mortgage branch cannot sustain itself without a steady flow of new inquiries. Effective marketing is essential for the success of a mortgage branch.

There Are Multitudes of Ways for a Mortgage Loan Originator to Drum Up Business:

• Realtor referral relationships
• Builders
• Attorneys
• Accountants
• Financial professionals
• Past clients
• Consumer referrals
• Purchased mortgage leads
• Organic search traffic
• Social media
• Video
• Email marketingCommunity outreach
• Networking
• Direct-to-consumer advertising
• Digital: Effective business generation strategies can vary significantly among MLOs.
• What works for one may not work for another.
• There are originators who build businesses that rely on a network of realtors.
• Others work on complex loan scenarios and earn referrals from other mortgage professionals.
• There are originators who work on leads from the web or work on search engine optimization.
• Regardless of the referral method, acquiring each customer involves a cost.
• These costs may include financial investment, time, marketing, advertising, technology, content creation, compensation, and commissions.
• A sustainable mortgage branch requires a reliable system for attracting borrowers.

What Creates a Sustainable Mortgage Business

A solid third-party referral network is an asset that can be valuable to an MLO’s business. Real estate professionals are careful not to damage their reputation by referring clients to untrustworthy loan officers. To gain the credibility needed to be referred by real estate professionals, an MLO must be dependable and proficient with communication, problem-solving, and interpreting loan guidelines.

That relationship is critical when the borrower does not fit the lender’s ideal loan scenario as determined by the lender’s automated underwriting system.

An MLO recognized for solving complex mortgage issues is likely to receive referrals from peers who are less focused on business growth. No single business model is inherently superior. MLOs should determine the type of mortgage business they wish to build before selecting a company to join. The mortgage net branch P&L model has become less prevalent and is considered outdated in recent years.

MLO Career Opportunities at Mortgage Bankers and Direct Lenders

Many mortgage bankers and direct lenders used branch opportunities to attract experienced mortgage professionals for whom the structure of their business is an important motivator.

The Ideal Candidates Were Typically:

• Established mortgage brokers
• High-performing MLOs
• Producing branch managers
• Mortgage teams
• Sales managers
• Loan officers with a strong business orientation
• This model remains attractive to prospective recruits.
• An experienced MLO, rather than operating as a sole business concern, can run a branch of the organization, hire staff, and grow a team and a brand at the local level.
• Furthermore, the MLO can influence the branch’s profitability.
• As similar models have been implemented by more mortgage companies, normal competitive business practices have been observed.
• Over time, similar compensation plans tend to emerge across the industry.

The Problem with the Compensation Number

• This is often where confusion arises in MLO recruiting.
• One company could promote a high basis-point compensation plan.
• Another company could offer a plan with 100% commission.
• Another company could promote a plan with low corporate margins.
• Another company could offer a plan with better pricing.
• Another company could offer leads, MLOs, processors, technology, health benefits, retirement benefits, or marketing support.
• Compensation figures in recruiting materials or advertisements are of limited value without clear context.

For Example, MLOs Should Know the Retention Per Closed Loan.

• What are the monthly and tech fees?
• Who pays for processing and credit reports?
• Are there compliance, payroll, and branch fees?
• Are there pricing differences among various investors?
• Are there different compensation structures for borrower-paid and lender-paid transactions permitted?
• What are the obligations for early payoffs?
• Who absorbs pricing concessions?
• Who absorbs the cures or mistakes?
• What is the process when a borrower requires an exception?
• These questions are often more important than headline compensation figures.

There is No Such Thing as Free in Mortgage

• Everything is compensated at the end.
• All mortgage professionals should understand this key principle regarding compensation plans:
• No service or resource in the mortgage process is provided at no cost.Processors need to be compensated.
• Underwriters need to be compensated.
• Compliance professionals need to be compensated.
• Technology is not free.
• Licensing and insurance have costs.
• Advertising, management, and accounting require payment.
• Office space must be paid for.
• Leads are not free.
• There is a cost to run a corporation.
• The issue is not whether a mortgage company incurs expenses.
• All companies incur expenses, as expected.
• The more relevant consideration is how these expenses are allocated and who ultimately bears the cost.
• Understanding the model clarifies why mortgage companies should not be compared based solely on commission rates.

Lending Officer Compensation vs. Mortgage Pricing

Here’s where immense confusion exists.

• Restrictions under Federal Regulation Z [12 C.F.R. § 1026.3(j)] specifically concern loan originator compensation.
• Simply, in most circumstances, compensation to a loan originator cannot be considered to have increased or decreased as a result of the loan’s interest rate, the loan’s Annual Percentage Rate (APR), or any other term of a loan that may be considered to be a restricted term.
• Federal regulations also restrict dual compensation, in which the originator is compensated by both the consumer and another party for the same transaction.
• The CFPB says mortgage loan officers and brokers can be compensated in various ways, such as salary, a set amount per loan, a set percentage of the loan amount, and/or a combination of the above, as long as the rules allow.
• This is important because loan officer compensation, company revenue, lender pricing, discounts, and the consumer’s interest rate are related but distinct concepts.
• There is no maximum compensation rate for Mortgage Brokers of 2.75%
• This is a figure I have seen repeatedly in my years in the mortgage industry.
• This figure can be cited, but it should not be cited as a Federal Law-sanctioned maximum compensation for mortgage brokers of 2.75%.
• One concept often mistaken for mortgage broker compensation is the Qualified Mortgage points-and-fees cap.
• For most Qualified Mortgages of $100,000 or more, the federal points-and-fees limit is 3% of the total loan amount.
• There are several limits that apply to smaller loans by dollar amount, and these limits are subject to regulatory changes, detailed calculations, and adjustments.
• Under certain conditions, loan-originator compensation may also be considered points and fees.
• The rules provide extensive information on what is included and excluded, and on the treatment of compensation.

This Does Not Mean:

• “Every mortgage broker is legally capped at 2.75% YSP.”
• I do not endorse this assertion.

Do Mortgage Brokers Always Have Better Rates than Mortgage Bankers?

No, mortgage brokers do not always have better rates than mortgage bankers.

There are numerous times that I have seen the wholesale broker channel provide much better pricing than the retail mortgage banking channel.

However, this does not guarantee that a mortgage broker will consistently offer better rates than a mortgage banker.

Mortgage Pricing is Influenced By:

• Loan program
• Investor
• Credit profile
• Loan-to-value ratio
• Property type
• Occupancy
• Lock period
• Market conditions
• Company margin
• Compensation structure
• Discount points
• Investor adjustments
• Pricing concessions

Mortgage Broker vs Lender

• One significant advantage of the broker model is the choice of lenders.
• A mortgage broker typically partners with several wholesale lenders, and a retail loan officer works through the lender hiring that loan officer.
• The CFPB provides a similar description, stating that mortgage brokers typically work with multiple lenders, whereas mortgage loan officers typically work at a single lender.
• Having many wholesale relationships gives a broker more opportunities to compare pricing and guidelines.
• However, having more lender relationships does not guarantee the lowest rates.

What I Learned About Pricing While Operating a Net Branch

This is where my experience differs, and I have a different perspective on mortgage company recruiting.

I have worked under compensation structures in which I reduced the compensation I paid to my loan officers and to myself to improve our competitiveness.

However, at times, the rates and costs to our borrowers remained, frustratingly, significantly higher than I considered competitive, compared with the pricing I observed with smaller independent mortgage brokers.

Operating your own branch provides a new perspective on the mortgage business.

You do not only consider your commission, but also:

What is the rate the borrower pays?

What is the cost the borrower pays?

Are we competitive with the other lender?

What is the margin between wholesale/secondary-market economics and the price offered to the consumer?

What is corporate retaining?

What am I retaining?

Why is my compensation structure making me uncompetitive?

At this point, even a well-designed compensation structure may become irrelevant.

Long-term profitability and sustainability are unattainable if attractive compensation structures result in pricing obstacles for borrowers.

Why Intense Recruitment Efforts

The primary reason is financial gain.

More specifically, productive mortgage loan originators (MLOs) generate greater revenue. That’s why established mortgage loan originators (MLOs) are more attractive as recruitment targets.

A loan officer with a persistent database, relationships, referrals, staff, and consistent monthly production is even more desirable.

This is why mortgage companies invest in attractive recruitment initiatives.

• More Attractive Compensations
• Easier Rate Access
• Greater Lender Access
• Superior Technology
• Superior Processing
• Superior Support
• Comprehensive Loan Products
• Faster Loan Closings
• Marketing Support
• Better Benefits
• Greater Autonomy
• Employer recruitment efforts are not the issue.
• The issue arises when an MLO joins a company based solely on recruitment efforts, without conducting a thorough personal assessment.

Never Join a Mortgage Company Based Only on the Rate Sheet You See During Recruiting

Pricing for experienced loan officers is one of the first things they analyze.

Pricing for Loans is a Snapshot. The Components of Pricing Can Change as a Function of:

• Time
• Loan Investors
• Markets
• Margins
• Compensation structures
• Investor relationships
• Strategic company direction

For this reason, I advise against evaluating a mortgage company based solely on a single rate comparison. Instead, compare multiple realistic loan scenarios.

Consider These Transactions:

• FHA purchase
• VA purchase
• Conventional purchase
• Conventional refinance
• Jumbo
• Low-credit borrower
• High-balance loan
• Investment property
• Non-QM loan
• Analyze the entire transaction.
• Review the rate.
• Review the points.
• Review lender credits.
• Review the adjustments.
• Review the compensation.
• Review the underwriting.
• Review the processing.
• Review the turn times.
• Review what the borrower receives.
• This analysis provides far more value than any recruiting presentation.

The Mortgage Banking Industry had Retail Loan Officers interested in Broker Loan Officer platforms with access, independence, and alternative compensation structures.

Competitors Saw the Changes

There was a disruption in the Mortgage Recruiting Industry.

The Meaning Behind “100% Commission”

• Mortgage Loan Originators need to understand the significance behind the phrase “100% commission.”
• In some cases, it can be a valid compensation structure.
• However, “100%” does not mean the Mortgage Company is operating at no cost.
• It is important to understand the context surrounding the “100%” statement.

Some of the Following May Occur:

• Transaction Fees
• Monthly Fees
• Fees for Technology
• Fees for Processing
• Administrative Fees
• Branch Fees
• Payroll Fees
• Corporate Fees
• Minimum Production Requirements
• Various Compensation Structures
• Early Loan Payoff Fees
• A 100% compensation structure is not inherently bad.
• For the right individual, it can be highly beneficial.
• Understanding the compensation structure is more important.
• Do not compare compensation rates between companies without understanding the net income generated by the same loan at each company.
• The net income is what truly matters.

Without Competitive Rates, Compensation Gets Meaningless

• Suppose Company A offers a compensation plan of 200 basis points, and
• Company B offers a plan of 150 basis points.
• Obviously, Company A looks more competitive.
• Yet, what if Company A’s borrower pricing is consistently […]

Support Staff Are Critical to the Success of a Mortgage Branch

The best of the best mortgage loan originators learn that there are limits to their capacity.

At a certain point, it becomes impossible to handle every borrower inquiry, manage employees, maintain referral sources, and oversee marketing and underwriting issues alone. Attempting to manage every aspect of the process is unsustainable.

Every successful mortgage operation relies on strong support staff.

A Good Mortgage Operation Would Have:

• Loan officer assistants
• Processors
• Contract processors
• Disclosure specialists
• Setup staff
• Underwriting support
• Compliance staff
• Closers
• Post-closing
• Marketing professionals
• Conversely, the lowest-cost company may not be the most profitable if significant time is spent on support tasks instead of originating loans.

Questions Every MLO Should Ask Before Joining a Mortgage Company

Before you go to another company and bring your license, team, clients, and branch along, make sure you get answers to the questions that are important to you.

• Compensation
• What am I compensated for?
• Which company deduction is taken before my payment?
• Are there monthly minimums?
• Are there per-file charges?
• What happens with early pay-offs?
• How do you manage pricing concessions?
• What do you charge on an FHA, VA, Conventional, Jumbo, and Non-QM loans?
• Can you show me live comparisons?
• How do you set your margins?
• Can you be more flexible with pricing?
• How do you manage exceptions?
• Lender and Investor Access
• How many lenders do I actually have access to?
• Which ones will I really use?
• Do I have access to specialty investors?
• If one lender cannot approve my borrower, then what?

Mortgage Underwriting

• Do you offer ‘manual’ underwriting?
• How do you escalate difficult loans?
• Can I speak with underwriting?
• What is the normal turnaround time?
• Does the company have lender overlays?

Mortgage Processing

• Is processing done in-house or outsourced?
• Who pays in this case?
• Can I use my own processor?
• What is the responsibility of the processor?

Compliance

• Who looked at the advertisements?
• How long does it take to get approval for marketing material?
• Who handles licensing issues for the state?
• How are branch examinations conducted?
• What compliance tasks does the branch take responsibility for?

Technology

• Which LOS do you use?
• What CRM do you provide?
• Is there an additional cost?
• Does the technology actually integrate with my workflow?

Marketing

• Does the company generate leads?
• Who keeps the leads?
• Who possesses my personal database?
• Can I market under my own approved brand or DBA, as the case may be?
• What happens to my database when I leave?

Employment and Exit Terms

• Are there ‘restrictive’ covenants?
• What happens to the loans in my funnel when I resign?
• What happens to unpaid commissions?
• Who owns branch-generated leads?
• What happens to employees associated with it?
• It is essential to review the contract directly.
• Exercise caution regarding information provided during recruitment. in recruiting.
• Exercise caution when moving a mortgage business that you built.
• Moving a mortgage business is relatively simple when you are an individual loan officer with no direct reports and a small pipeline.
• However, moving an entire mortgage business is a different undertaking.

You May Have:

• Employees
• Licensed MLOs
• Active borrowers
• Locked loans
• Relator partnerships
• Vendor partnerships
• Office agreements
• State licenses
• Advertising
• Web pages
• Phone services
• Email accounts
• CRMs
• Databases
• Pay
• Registered.

Therefore, a branch transition should be approached as a business decision. An attractive compensation plan alone should not justify moving your business to a new mortgage company. Mortgage markets change, and business models have to adapt to survive slow market years. The mortgage industry has good years and bad years. When rates are low, consumers are confident and make purchases. The reverse is also true. site is true. When rates start to rise, and consumer confidence is low, purchase transactions become practically non-existent. This is when the true nature of a mortgage business model emerges.

A Mortgage Business That Relies on Refinances May Struggle

An MLO without referral partners may have a business model that is not viable and may require adjustment. A strategy reliant on expensive purchased leads may become cost-prohibitive. Therefore, mortgage professionals should build their businesses to succeed in both favorable and challenging market conditions.

What Matters More Than the Best Compensation Plan

After years of operating my mortgage business, I believe that achieving stability and long-term competitiveness is more important than a high compensation figure.

I Want to Know:

• Can I compete for business?
• Can I close deals or loans?
• Are there answers from the processors?
• Can I reach management?
• Is the operation a trusted partner?
• Can the borrowers get better pricing?
• Can I build my business?
• Am I able to keep or retain loyal professionals?
• Do I have the opportunity to develop partnerships?
• Can the company survive a tough mortgage market?
• Can the branch remain profitable after all expenses? These questions are more significant than headline compensation figures presented during recruitment.

My Biggest Lesson From Operating a Mortgage Net Branch

Based on my experience, my primary advice to a loan originator considering a mortgage net branch is as follows:

The most important thing to consider should be the overall platform of the mortgage business being started, not compensation.

• Compensation is important.
• Pricing is important.
• Underwriting is important.
• Technology is important.
• So are the processors.
• Lender choice is important.
• Compliance is important.
• So is marketing.
• So is management.
• All of these factors must be considered collectively.
• I gained this insight through my experience operating a mortgage net branch.
• At times, I reduced my commission to secure better deals for borrowers.
• I often questioned whether the economics of a particular model were sound, especially when reviewing the P&L and realizing the compensation plan appeared very different in practice.
• That experience taught me a lesson that I use when evaluating mortgage lenders.

The Best Mortgage Company Depends on the MLO

Not every mortgage company can be the best for every loan officer. A new loan officer may need a lot of support, like training, leads, supervision, and a strong operating team. Compensation, pricing, and lender access may be more important to a high-producing self-generated loan officer. Recruiting and management tools may be important for a person who leads a team of loan officers.

A person who runs a loan officer branch may be interested in P&L, staffing, marketing, accounting, branding, and the branch’s long-term profitability.

A person who does manual underwriting may appreciate flexibility more than someone who does automated underwriting with high-credit, conventional borrowers. Understand your business thoroughly before selecting a platform. Selecting a highly regarded mortgage company may not align with your business approach if you lack a thorough understanding of your own operational needs.

Final Thoughts on the Mortgage Net Branch P&L Model

The mortgage industry faces many challenges, but it can be a very rewarding career. Thinking like a loan officer is not enough with the mortgage net branch P&L model. This requires adopting the perspective of a business owner. That includes knowing where the money is coming in, where the money is going out, what the borrowers are receiving, what the employees need, and whether the platform will hold up against competitors. I have had first-hand experience with developments in the mortgage industry while having my own mortgage net branch since 2015. I have learned enough to recognize that what is now the hottest compensation model will be old tomorrow.

• Things change.
• Model change.
• Things change.Markets change.
• Things change.
• People change.
• Your reputation and your book of business are harder to replace.
• Protect these assets diligently.
• Take responsibility, reTake responsibility, review all documents carefully, and ensure you fully understand their implications before signing or joining a Mortgage Net Branch or mortgage company.n really 100%?
• It could be 100% of whaIt may represent 100% of the compensation as defined by the company’s plan, but this does not guarantee the absence of additional costs.
• Before comparing compensation plans, MLOs should review transaction costs, monthly fees, technology expenses, processing fees, branch fees, early pay-off charges, and other related costs.
• Payment capped at 2.75% by the federal government?
• There’s no federal rule that sets the upper limit on mortgage broker compensation at 2.75%.
• Federal mortgage regulations include separate requirements for loan-originator compensation, points and fees on qualified mortgages, high-cost mortgages, steering, and dual compensation.

Can an MLO Earn Higher Compensation by Charging a Borrower a Higher Mortgage Rate?

In most cases, Federal Regulation Z prohibits compensation to loan originators based on the mortgage rate or any other prohibited terms.

Do Mortgage Brokers Always Have Better Terms Than Mortgage Bankers?

• No.
• While a broker may have an advantage since they can choose among several wholesale lenders, mortgage pricing depends on many factors, including the lender, investor, loan program, borrower, margin and compensation, market conditions, etc.
• MLOs and borrowers should compare the terms of individual transactions.

What Should an MLO Compare Before Changing Companies?

• Compare actual borrower pricing, compensation, lender access, underwriting, processing, technology, corporate fees, marketing, compliance, management, and the terms of the contract for what happens if they leave and the requirements for making a transfer.

Should I Join the Mortgage Company Offering the Highest MLO Compensation?

• Maybe, maybe not. The highest gross compensation could mean higher expenses, less competitive pricing, poor operations, limited loan programs, or weaker support.
• A better comparison is MLO expected net income, closing conversion, borrower competitiveness, and the ability to build a book of business.

Is Running a Mortgage Net Branch Worth it?

• If the MLO can bring in business, then maybe.
• If the mortgage broker is also prepared to take on the additional tasks of managing a branch, including running operations, compliance, marketing, and profitability, then it could be worth it for the mortgage broker.
• Running a mortgage branch is not the right choice for MLO’s looking to avoid the additional responsibilities of originating loans.

Author’s Note:

This guide is based on my own personal experiences in the mortgage industry and includes my own observations. I have provided links to industry business models or companies for context, but they are not meant to suggest any wrongdoing. Mortgage company compensation, pricing, employment, licensing, and branch structures vary based on the federal and state laws and agreements.

[Bruce]

Democratic socialism advocates integrating a democratic political system with a socialist economic system. Rather than viewing democracy and socialism as opposing concepts, proponents argue that genuine democracy must encompass economic democracy.

Democratic socialism is based on economic democracy, which holds that major resources such as factories, utilities, and industries should be collectively owned by the public, workers, or the state rather than by private individuals. It also promotes workplace democracy by encouraging employee participation in decision-making. Additionally, it aims to limit market influence over essential services such as healthcare, housing, and education.

Democratic socialists also support political democracy, emphasizing individual freedom, fairness, the rule of law, civil rights, and a multiparty system. This approach contrasts with authoritarian socialist systems, such as Soviet Socialism or Maoism, which centralize power and restrict political freedoms.

Democratic socialists prioritize redistribution and social equality. They support establishing a strong welfare state, advancing social democracy, and reducing class disparities through wealth redistribution and labor rights protections.

Democratic socialism shares features with social democracy and authoritarian socialism, but remains distinct. Social democracy aims to reduce capitalist inequalities through government programs while keeping capitalism. Democratic socialists, however, see capitalism as fundamentally flawed and seek a full transition to a socialist economy. Authoritarian socialism involves state control of the economy and single-party rule, which opposes democratic socialism’s core principles.

In recent American politics, the term ‘democratic socialism’ became prominent after 2016, largely due to figures like Bernie Sanders and Alexandria Ocasio-Cortez. However, many of their policies, such as Medicare for All and tuition-free public college, align more with social democracy since they do not call for public ownership of industry. Democratic socialism began in Europe in the late nineteenth century, emerging with Marxist socialism and labor unions. It often responded to Soviet-style authoritarianism.

https://www.youtube.com/watch?v=RA9hArZKYq4

[Bruce]

Heres another informative video about German Shepherd Training.

https://www.facebook.com/share/v/1Hc8E9xxxx/

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3.9K views · 51 reactions | How to Housebreak and Potty Train your German Shepherd Puppy https://germanshepherdman.com/ | German Shepherd Man

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[Bruce]

Here’s an informative training video about German Shepherd dogs.

https://germanshepherdman.com/?fbclid=IwdGRzaATWYfFjbGNrBNZh5mV4dG4DYWVtAjExAHNydGMGYXBwX2lkDDM1MDY4NTUzMTcyOAABHvl0MtDgxUnzxASUydi5n4L9F3ZNOpBQAKSqN72-Vn-s6SA2XFlSUuUrvRmx_aem_QXqDy7FTGjNdhaHEAvWXpQ

germanshepherdman.com

German Shepherd Man

German Shepherd Man

[Bruce]

Can a Mortgage DBA Be Transferred from NEXA Lending to Coast 2 Coast Mortgage Lending Through NMLS?

Short Summary Questions and Answers

1. Can a mortgage DBA be transferred from one mortgage company to another through NMLS?

That is the main question. I need to know whether the DBA Gustan Cho Associates can be transferred, reassigned, or released from NEXA Lending to Coast 2 Coast Mortgage Lending, LLC through NMLS or state regulators.

2. Does NEXA need to cancel the DBA first?

If a direct transfer is not allowed, does NEXA Lending first need to cancel, surrender, or remove Gustan Cho Associates from its NMLS and state records before Coast 2 Coast Mortgage Lending, LLC can apply to use the same DBA?

3. Is a DBA considered an “Other Trade Name” in NMLS?

My understanding is that NMLS may treat a DBA as an Other Trade Name on the company record. I would like confirmation from compliance experts, licensing attorneys, or NMLS specialists.

4. Does each state have different DBA rules?

Does the answer depend on the state? If the DBA was used in multiple states, does each state decide whether the name must be canceled, amended, released, or refiled?

5. Can NEXA and Coast 2 Coast coordinate the transition?

Is there a way for NEXA Lending to release or remove the DBA and for Coast 2 Coast Mortgage Lending, LLC to file for the same DBA without creating a licensing, advertising, or branding gap?

6. Who controls the DBA if the brand belongs to me?

If Gustan Cho Associates is my long-standing brand and was only used under NEXA because I operated a branch there, does NEXA have any continuing right to hold or delay the DBA after my resignation?

7. Can I stay sponsored by NEXA in states where Coast 2 Coast is not licensed?

If Coast 2 Coast Mortgage Lending, LLC is not licensed in certain states, can I temporarily remain sponsored by NEXA in those states, if allowed by state law, company policy, and NMLS sponsorship rules?

8. Are DBA termination fees normally charged to the branch ledger?

If state fees are required to remove or terminate the DBA, can those fees normally be charged to the branch P&L, ledger, or reserve account if funds are available?

9. What documents should I request from NEXA?

I would like to request a state-by-state list showing which states list Gustan Cho Associates as a DBA, which filings are required, which fees apply, which filings have been submitted, and which approvals are still pending.

10. What is the cleanest compliance process?

Would the cleanest process be for NEXA to remove Gustan Cho Associates from its records, Coast 2 Coast to add Gustan Cho Associates as a DBA or Other Trade Name, and each state regulator to approve the change where required?

Goal

My goal is to transition the Gustan Cho Associates DBA from NEXA Lending to Coast 2 Coast Mortgage Lending, LLC professionally, legally, and without unnecessary delays, duplicate filings, or consumer confusion. Any guidance from mortgage compliance professionals, NMLS experts, licensing attorneys, state regulators, or branch managers would be appreciated.

[Bruce]

Thank you for raising this issue. I understand the confusion, as terms such as “mini-correspondent,” “HUD-approved,” and “1099 versus W2” are often conflated. I will clarify each term below.

First, the Designation “Mini-Correspondent HUD-Approved” Does Not Exist.

This distinction is important, as it changes the context of your inquiry. Historically, HUD had a separate approval category called “Loan Correspondent” (or “Mini-Eagle”), distinct from a full “Mortgagee” (Full Eagle). Currently, HUD no longer approves loan correspondents, and mortgage brokers are not required to obtain HUD approval. They may only underwrite loans sponsored by their Direct Endorsement (DE) mortgagee.

Currently, HUD approves companies under one of four Mortgagee types:

1. Supervised
2. Non-supervised
3. Government
4. Or investing.

A company approved as a Non-supervised Mortgagee with Direct Endorsement (DE) authority may underwrite and endorse FHA loans in its own name. The industry informally refers to this arrangement as a “mini correspondent.” However, this is not an official HUD designation; rather, it describes a business model in which the company closes loans in its own name using a warehouse line and subsequently sells them, unlike a full mortgage banker, which retains a servicing portfolio.

Therefore, ABC Mortgage Broker must obtain approval as a HUD Non-supervised Mortgagee with Title II Direct Endorsement (DE) Authority.

Next, I will address the question regarding 1099 versus W-2 classifications. That “you can’t do it with 1099s” is somewhat overstated, though not entirely inaccurate, for the following reasons:

• No federal law or HUD regulation explicitly prohibits 1099 classifications for loan originators.
• The Consumer Financial Protection Bureau’s (CFPB) Loan Originator Compensation Rule under Regulation Z allows both W-2 and 1099 arrangements.
• The Nationwide Multistate Licensing System (NMLS) also accommodates registrations for both, which would not be possible if 1099 arrangements were entirely prohibited.

However, HUD’s use of the term “employee” and its direct employment requirements are more limited in scope and do not apply to all mortgage loan originators (MLOs):

• SAFE Act Compliance and Sponsorship: According to HUD Handbook 4000.1, the mortgagee and its employees must comply with the SAFE Act, and the mortgagee must register and sponsor the employee in the NMLS.
• This applies equally to both W-2 and 1099 loan originators; the key factors are sponsorship and supervision, not tax classification.
• Direct Endorsement Underwriters: HUD has taken a stronger position requiring actual employment (as opposed to contracting) of its Direct Endorsement Underwriters, given that the authority to underwrite and bind insurance to the FHA is a non-delegable function.
• Use of Contractors (HUD Handbook 4000.1, I.A.6.j): HUD specifies which functions may be performed by contractors instead of employees.
• This section determines whether a 1099 MLO may perform certain loan origination functions and is more authoritative than informal legal opinions.
• Previously, the “Dual Employment” provision required employees to work for only one mortgagee.
• This requirement was rescinded by a HUD Mortgagee Letter, making this argument against 1099 arrangements invalid.

Additional Supporting Evidence

For example, The Loan Factory, and Barrett Financial Group all operate as HUD-approved lenders employing both 1099 and W-2 MLOs. If there were an absolute ban on 1099 arrangements, these companies could not operate as they do. This strongly indicates that a total prohibition does not exist.

The Primary Limitation Comes From State Law.

In practice, state law is usually the primary limitation, not HUD regulation. For example, New Jersey requires MLOs to be W-2 employees, while Florida allows 1099 contractors. A multi-state broker employing both types would not be disqualified by HUD but must comply with each state’s legal requirements. A 1099 arrangement allowed in Florida may violate New Jersey licensing laws, regardless of HUD’s position.

The individual advising ABC Mortgage Broker that “you can’t get HUD-approved with 1099 MLOs” is partially correct, since HUD approval as a Non-supervised Mortgagee/DE lender requires certain staff to be W-2 employees, and industry practices reflect this.

However, this is not entirely accurate. HUD regulations require Direct Endorsement underwriters to be directly employed, and there are significant state-by-state differences in MLO compensation requirements. Before establishing a compensation structure, I recommend reviewing HUD Handbook 4000.1 Sections I.A.6.e (Employee Compensation), I (Staffing), and j (Use of Contractors), and consulting a mortgage regulatory counsel to address state-specific compensation issues. These present the primary compliance risks, rather than any federal prohibition on 1099 arrangements.

[Bruce]

With all due respect, your response does not tell me a real case scenario situation. The purpose for my referring a Kentucky licensed real estate agent is so I can get the 25% referral commission and continue to develop a strong working relationship with the Kentucky real estate agent and managing real estate broker. I am an Illinois licensed real estate agent and a licensed MLO in 40 plus states and will be the loan originator for the Kentucky homebuyer. All Kentucky borrowers without a real estate agent will be referred to the Kentucky real estate agent. I want to develop relationships with as many real estate agents and brokers in the 40 states and create a preferred referral partner network with my sponsoring mortgage broker and real estate agents and brokers on states I am licensed in. How can I set up, the 25% referral real estate commission I will be compensated is sent by Kentucky managing broker to my Illinois managing real estate broker, correct? Does the managing brokers get a cut on the 25% realtor referral commission? How do I go about asking other MLOs to refer mortgage loan applicants in other states where the homebuyer does not have a real estate agent? How do I go about getting potential real estate agents in other states and posting them on my mortgage website in the preferred real estate partner directory?