[Gustan Cho]

Here is my 3 pound toy poodle 🐩 ❤️ 💖 💕 😀 Lilly watching out for goffers and squirrels. She’s mesmerized with little rodents smaller than her.

[Gustan Cho]

TRID Mortgage Loan Officer Compliance Training – Advanced

Advanced TRID training helps mortgage loan officers avoid delayed closings, unexpected fee increases after closing, and costly compliance errors. Basic training covers when to send the Loan Estimate and Closing Disclosure, but advanced sessions dive into the specific timing rules, required redisclosure documents, and the circumstances under which lenders are responsible for cost increases.

The File Closing Point

Once the borrower receives the Loan Estimate, they need to confirm they want to move forward. Until then, the lender or broker may charge only a legitimate credit report fee. Silence from the borrower does not count as agreement.

Fees for processing, appraisal, or underwriting cannot be charged until the borrower has both received the Loan Estimate and agreed to continue.

Advanced training should stress the need for clear documentation. Each file must include the Loan Estimate and specific proof that the borrower agreed to continue. General notes such as “borrower wants to proceed” are not sufficient, especially when there are multiple Loan Estimates with different terms.

Many MLOs Are Wrong About When Application Clock Starts

Under TRID, an application is considered submitted when the lender has the borrower’s name, income, Social Security number or other credit information, property address, estimated property value, and requested loan amount.

The lender must send the Loan Estimate within 3 business days of receiving all 6 items. Waiting for additional documents such as pay stubs, tax returns, or bank statements does not pause this timeline.

Experienced MLOs need to recognize when a casual conversation turns into a legally binding application. This is especially important when gathering leads through phone calls, texts, online forms, or CRM systems, where information may come in gradually.

Examples of Legitimate Changed Circumstances and Poor Estimates

A new Loan Estimate cannot be used to correct an error from underestimating costs. Under TRID, a true change in circumstances includes unusual or unexpected events, new information about the borrower or transaction, or other surprising details.

Updates to the Loan Estimate may be allowed for changes in borrower eligibility, rate locks, expired Loan Estimates, borrower requests, or some delayed construction settlements.

Valid reasons to update a Loan Estimate include discovering a farm designation in an appraisal, finding an unreleased lien that needs extra title work, a decrease in verified income, or a change requested by the borrower. Underestimating appraisal costs, unexpected title company fees, or missing fees are not valid reasons to update the estimate.

Timing for Redisclosure: The Three-Day Rule with Some Exceptions

Once a lender has enough information to require redisclosure, they usually have three business days to provide it. If the rate is locked after the first Loan Estimate, a revised estimate with the locked rate, points, lender credits, and other rate-related items must be sent to the borrower within three business days of the lock. The estimate must reach the borrower at least four business days before closing. After the Closing Disclosure stage, any changes must be shown with a corrected Closing Disclosure, not by sending another Loan Estimate.

Fee Tolerances: Who Covers Costs When They Go Up?

TRID Categorizes Costs Into Three Broad Categories.

• The zero-tolerance category covers lender and broker fees, affiliate fees, required services the borrower cannot shop for, and transfer taxes.
• If a valid redisclosure is not made on time, these fees cannot go up.
• 10% aggregate tolerance category includes recording fees and certain third-party services that the borrower did not select.
• In this category, the total charges may increase by no more than 10%, even if an individual fee increases by more than 10%.
• The no-numeric-tolerance category includes prepaid interest and services the borrower selects. Lenders must provide the most accurate estimate possible and cannot use unsupported numbers.
• If there is an overcharge, the lender must refund the difference within 60 days of closing and update the Closing Disclosure to show the refund.

TRID Business Days: The Most Common Mistake.

• TRID uses two different definitions of “business day.”
• For the initial Loan Estimate and most revised Loan Estimates, a business day is any day when the lender’s offices are open to the public for most of their business hours.
• For presumed receipt rules, the seven-business-day Loan Estimate waiting period, and similar rules, a business day is any day other than Sunday or a federal holiday.
• For the Closing Disclosure waiting period, a business day means every calendar day except Sundays and federal holidays.
• It might seem compliant one day and not the next, depending on which business day definition is used.
• MLOs should never trust memory or a real estate agent’s calendar to count disclosure days.
• The important date is consummation, when the borrower is officially committed under state law.

A Corrected Closing Disclosure Restarts the Three-Day Waiting Period.

• Most changes to the Closing Disclosure do not restart the three-business-day waiting period.
• The borrower may receive a corrected Closing Disclosure at or before consummation in most instances.
• A new waiting period is required only if the APR exceeds Regulation Z’s limits, the loan product changes, or a prepayment penalty is added.
• Experienced MLOs should be able to spot these three triggers when reviewing a loan file.
• The rules require that the Loan Estimate be delivered on time.
• Both the Loan Estimate and the Closing Disclosure be accurate.
• Each Loan Estimate be updated for valid reasons; rate locks be shared and renewed promptly.
• The Closing Disclosure be provided and completed on time; and fees and lender credits be calculated correctly.

There are Four Redisclosure Questions to Answer When Considering Advanced Knowledge of the TRID Regulations:

1. What changed?
2. Why is this a valid TRID trigger?
3. When did the lender first become aware of this?
4. Was the disclosure issued on time, and was it the right one?

An advanced course should give participants hands-on experience with real loan files. It should include calendar-based drills, tolerance calculations, and realistic scenarios like Closing Disclosure delays, going far beyond just learning definitions.

[Gustan Cho]

Kim

Finally getting together and ready to kick ass. Welcome on-board and let go to the top.

[Gustan Cho]

Love my Chase and Skylar. Bailey, not too much.

[Gustan Cho]

In this episode of Greta Wire, Blagojevich discusses his indictment, imprisonment, sentence reduction, and subsequent pardon. He characterizes his case as an example of politically motivated prosecution, which he calls “lawfare,” and draws parallels to the legal challenges faced by Donald Trump.

Key Discussion Topics

The Vacancy of Obama’s Senate Seat

• • Blagojevich addresses the 2008 allegations that he attempted to sell the Senate seat vacated by President Obama.
  • Blagojevich asserts that his conversations were misinterpreted and contends that exculpatory evidence was excluded from his trial.

Federal Corruption Charges and Judicial Proceedings

• Blagojevich discusses the federal corruption charges that resulted in his 14-year prison sentence.
• He alleges that the prosecution relied on undisclosed evidence and maintains that the public has not had access to the complete, unedited recordings of his conversations.

Experiences During Federal Incarceration

• Blagojevich describes his daily routine during incarceration, the individuals he encountered, and the strategies he employed to manage the challenges of imprisonment.
• He recounts his participation in “The Jailhouse Rockers,” a prison band that performed Elvis Presley songs.
• Blagojevich discusses the emotional distress caused by prolonged separation from his family and emphasizes that his personal identity extends beyond his legal challenges.

Sentence Reduction and Prospective Pardon by Trump

• He supports his 2020 sentence reduction and anticipates a full pardon in 2025, expressing gratitude to Trump for the renewed opportunity.
• He discusses how these decisions have affected his public image and political prospects.
• Blagojevich’s case continues to generate public debate.
• Federal prosecutors stated he was recorded attempting to exchange the Senate seat for political favors.
• He was convicted on several corruption charges, with some convictions later overturned and others upheld.

This episode serves as Blagojevich’s personal defense and offers insight into his perspectives on politics, redemption, and life after incarceration.

This episode provides the most comprehensive post-pardon interview with Blagojevich, making it especially relevant for those interested in Illinois politics, the Obama Senate seat controversy, or legal complexities.

[Gustan Cho]

.

Your loan-to-value ratio puts you in a strong and secure financial position.

Your Current Situation

• Estimated Home Value: $620,000
• Current Construction Loan Balance: $155,000
• Cash Needed: $25,000
• Requested New Loan Amount: $180,000

Loan-to-Value (LTV)

A $180,000 mortgage on a $620,000 home gives you a low loan-to-value ratio of 29%.

With this setup, you would have about:

• $440,000 in home value you own ($620,000 – $180,000)
• Approximately 71% equity

Most lenders require a higher loan-to-value ratio, so with a 29% ratio, your ownership in the home is very strong.

Potential Solutions

Cash-Out Refinance

If you replace your construction loan with a new mortgage, you could receive about $25,000 in cash after closing costs.

• Pay off the $155,000 construction loan.

Construction to Permanent Loan

If your lender offers a One-Time Close or Construction-to-Permanent Conversion, you may be able to include the extra funds in your final loan.

Home Equity Loan or HELOC

Another option is to:

• Refinance or change the $155,000 balance and
• Obtain a $25,000 HELOC or 2nd mortgage.

For most people, getting a $180,000 first mortgage with a 29% loan-to-value ratio is usually the simplest option.

Criteria for Mortgage Approval

Lenders usually consider factors like your credit score.

• The borrower’s average income
• The borrower’s work history
• The borrower’s debt compared to income
• How the home is used (main home, second home, or rental property)
• Whether the home has its final approval certificate

Relevant Information

Use the following information to check your mortgage eligibility and find the best options. Is this your primary residence?

1. Which state is the home located in?
2. Approximately what is your credit score?
3. Are you working for someone else, self-employed, retired, or receiving disability income?
4. Has your home received its final certificate? With a home valued at $620,000, requesting a $180,000 loan is a careful choice and should meet most mortgage program requirements.

[Gustan Cho]

If a major bank advertises a 30-year fixed rate of 6.25% while the national average is between 6.5% and 6.7%, it makes sense to be skeptical. Rather than only verifying the rate, it helps to understand why it might be lower. For borrowers with strong credit, the typical 30-year fixed loan rate falls between 6.5% and 6.6%.

Who Can Get Chase’s 30-Year Fixed at 6.25%?

Even though these rates are widely advertised, only applicants who meet strict requirements will qualify.

• 740+ credit score
• At least 25% down
• Primary residence
• Low loan-to-value
• Conforming
• Significant reserves
• DTI < 45%
• Relationship banking
• Certain lock
• Certain property

Chase explains that your rate depends on factors like your credit score, down payment, loan details, and more.

Is Chase Masking Discount Points?

• It’s possible that’s the case.

It’s a good idea to look beyond the interest rate and compare it to the annual percentage rate (APR).

• APR = 6.58%

Often, the gap between the interest rate and the APR indicates whether points or extra fees are added to the loan.

• Chase explains that each discount point typically costs about 1% of the total loan amount.

When You See an Advertised Interest Rate, Ask About These Things:

1. What is the APR?
2. How many discount points are required?
3. Is lender compensation built into the pricing?
4. Are there origination fees?
5. Is there underwriting or processing?
6. Are there relationship pricing discounts?

Why Can Chase Offer Lower Rates Than Many Other Mortgage Companies?

Several main reasons help explain why these rates can vary so much.

Diversified Revenue Streams

Chase earns money from many sources, while independent mortgage banks rely only on mortgages. These sources include:

• Deposits
• Wealth management
• Credit cards
• Commercial lending
• Investment banking

For banks, mortgages are often more about bringing in new customers than making a profit.

Relationship Discounts:

• Chase offers mortgage rate discounts to customers who keep large balances in deposit or investment accounts.
• In some cases, these discounts can reach up to 1.00%.
• If you have $1 million or more parked with Chase, you are likely to unlock rates that most applicants can only dream of.

Portfolio Lending:

• Large banks can keep loans in their own portfolios, something independent lenders usually cannot do.

Temporary Rate Promotions

• In 2025 and 2026, Chase ran special mortgage rate promotions, reducing rates by up to 0.25%.
• However, these deals may come with hidden extra fees.
• Most large lenders use third-party services and charge related fees for required reports.
• Flood certification
• Tax service
• Title
• Recording

Here are Some Potential Third-Party Fees to Watch For:

• Processing fee
• Underwriting fee
• Administration fee
• Technology fee
• Funding fee (non-VA)
• Document preparation fee

Fees caFees can differ greatly between lenders. The Loan Estimate reveals the real cost of a loan. Two lenders might offer the same rate, but one could charge $4,000 more in fees.

Are Competitive Rates Today?

Competitive Rates Apply to Borrowers with the Following Qualifications:

• 760+, FICO
• 25% Down
• Single-family, owner-occupied,
• Conforming loan
• Significant reserves

Current Mortgage Pricing Suggests the Following Ranges:

• 6.25% to 6.625% with varying credits or points
• 6.50% to 6.75% is close to par. Rates depend on the lock-in date, lender, lock period, loan location, loan type, loan-level price adjustments (LLPAs), and other market factors.

Mortgage Brokers Often Work with Wholesale Lenders, Who Can Offer Lower Rates Because Their Operating Costs are Lower Than Those of Retail Banks.

Powerful Wholesale Lenders Often Find Themselves Competing Against the Following:

• United Wholesale Mortgage
• Rocket Pro
• Pennymac
• Homepoint (where available)
• Flagstar Bank
• Rate

Experienced mortgage brokers can often use their network of wholesale lenders to find better rates or lower fees for qualified borrowers.

Gustan Cho Associates (GCA) may not always have the lowest rates, but stands out because of a wide range of products and services, including:

• Market access to wholesale lenders
• The ability to shop lenders
• Manual underwrite
• FHA and VA expertise
• Non-QM
• High DTI
• With fewer restrictions than many lenders, prime borrowers can get the best rates by shopping around and comparing offers from different investors.

What I Think

If Chase advertises a 6.25% rate, I don’t believe it’s automatically a scam.

However, there is almost always a catch or a specific reason for a rate that low.

To decide if it’s a good rate, I look closely at the details.

• Interest Rate
• APR
• Total Lender Fees
• Daily Fees
• A 6.25% rate with two points could end up costing more than a 6.5% rate with a lender credit.
• Lately, mortgage rates have been unpredictable, influenced by factors such as oil prices, inflation expectations, Treasury yields, strong job markets, and unrest in the Middle East.
• When tensions with Iran eased, oil prices fell, and Treasury yields stabilized.
• It’s still unclear if this will lower mortgage rates, since it depends on how the bond market sees inflation.
• Right now, mortgage prices mostly track the 10-year Treasury yield and mortgage-backed securities, rather than any single global event.

[Gustan Cho]

It looks like automated underwriting does not capture the full picture of your financial situation.

• Your median credit score is 583.
• You have two years of uninterrupted W-2 employment.
• You receive $1,663 per month in tax-exempt VA disability income.
• Your employment income is $3,200 per month.
• For qualifying, your VA disability income is actually counted as more, which boosts your total qualifying income.
• Your high residual income is a major advantage in VA underwriting.
• You are looking to purchase a home for $200,000, which is a typical loan amount.

Rocket Mortgage and most large lenders use automated underwriting. If the system does not approve you, they usually will not consider manual underwriting due to their own rules.

Reason for Rocket’s $120,000 Limit

Such a Limit May be Due to:

• An automated underwriting system results in a higher debt-to-income ratio.
• Limited depth of credit profile.
• Recent derogatory credit events.
• Internal lender overlays.
• If the automated system gives a negative result, it can reduce the highest loan amount you can qualify for.

Lender Overlays are not VA Requirements

The Value of Manual Underwriting.

With VA manual underwriting, your steady job and strong leftover income matter even more. They also consider your rent history, other positive factors, and disabilities. VA loans are more flexible than most, so your high leftover income really helps you.

Information Needed to Assess $200,000 VA Loan Eligibility

To Pursue Manual Approval, Please Provide the Following:

• Auto loans
• Personal loans
• Student loans
• Credit cards
• Child support

1. Location of the property (County)
2. Estimated property taxes
3. Estimated homeowner’s insurance cost
4. Are there charge-offs, collections, late payments, etc.?
5. Are there bankruptcies, foreclosures, or repossessions?

Basic Key Calculations Based on the Income Details you Provided:

• W-2 income = $3200/month
• VA Disability = $1663/month
• Total monthly income = $4863
• VA disability income is tax-free and counted higher when figuring out if you qualify.

A $200,000 VA Loan May Result in a Monthly Payment of $1,400 to $1,700, Depending On:

• Interest rates
• Tax implications
• Insurance policies
• HOA fees

With your income, this payment should be affordable as long as you keep your debts low and keep a high leftover income.

Additional Considerations

Ask Loan Providers: Do you Offer True VA Manual Underwriting?

• Do you have a minimum credit score requirement that exceeds VA requirements?
• Would you consider a file with a median score of 583 and unfavorable AUS results for manual underwriting?
• What is your residual income calculation for VA manual underwrites?
• Have you closed VA manual underwrites for loans with a credit score under 620?

Many Lenders Say They Offer VA Loans, But Only a Few Truly Provide Manual Underwriting

.If You Provide the Following:

• Monthly debt obligations,
• The State and County where the property is located,
• The sales price,
• An estimate of the property tax,
• An indication of whether you are exempt from the VA Funding Fee due to a service-connected disability,

If you share this information, I can let you know if a $200,000 VA loan is possible for you and explain the reason behind the $120,000 limit.

VA DTI Manual Underwriting Guidelines on VA Loans

[Gustan Cho]

This topic and subject matter are very important. Many team leaders, mortgage net branch managers, and owners of mortgage brokerage companies neglect to do a thorough due diligence on their current P and L on their current company and pro-forma P and L on a new prospective company. There should be many existing free templates where you do not have to spend hundreds of dollars on an expensive CPA. Just from the top of my head, the following are important subject matters that need to be covered and once covered, you can expand from here using real data and numbers. Do compare and contrast.

• Partnership possibilities
• Origination platform: Organic leads through consumer direct, Buying leads, Realtor partnership, etc.
• Previous Employer vs. New Employer comparison
• Branch economics
• Long-term vision
• Compensation structures

Mortgage Due Diligence Template

Mortgage branch managers, team leaders, brokers, and owners often face the same issue: failing to conduct sufficient due diligence before making business decisions.

Whether the goal is to start a mortgage net branch, open a new mortgage brokerage, join a new firm, merge with a branch, form a partnership, build a new team, or buy a business, everyone should focus on facts, numbers, and the long-term effects of the decision, rather than just gut feelings. Surprisingly, some professionals don’t do a full profit-and-loss review of their current business before deciding it’s better than other options. Others focus only on profits and ignore costs such as support, compliance, lead generation, technology, growth, and recruiting.

Recruiting costs.

For any big business decision, carefully analyze both your current and proposed business models. Always use real facts and numbers instead of just estimates.

Fortunately for mortgage professionals, there are many free resources and due diligence templates to do an initial review. You can use these tools to check your operations before hiring an expensive CPA or consultant. After this first review, you can update it with your actual financial numbers. Going with a new mortgage company.

• Starting a mortgage net branch.
• Opening your own independent mortgage brokerage.
• Combining two branches.
• Getting a new company.
• Starting a joint venture.
• Making a recruiting partnership.
• Setting a marketing agreement.
• Going into more states.

Knowing the goal provides direction on which variables will be most important.

Step 2: Determine the Worth of a Partnership

Knowing your goal helps you figure out which factors matter most.ve.

Some things to think about are as follows:

• What do each of the people involved in the partnership have to offer?
• How will the profits be shared?
• Who has power over the business?
• Who will be in charge of hiring?
• Who has ownership of the leads and database?
• Who is in charge of compliance?
• How will disagreements be settled?
• What will the partnership look like if one person leaves?

A partnership only works if there are well-defined goals before the partnership starts.

Step 3: Examine. A partnership works best when everyone agrees on clear goals from the start.gination.

Analyze how each method of obtaining leads is beneficial and/or detrimental:

Consumer Direct Marketing: Look at how each way of getting leads helps or hurts your business:

• Consumer education
• Website traffic

Purchased Leads

• Cost per lead
• Conversion rates
• ROI (Return on Investment)
• Quality of Leads

Referral- Based Business

• Realtor relationships
• Builder relationships
• Attorney referrals
• Financial planner referrals
• Past client referrals

Hybrid Model

Using several lead sources in a partnership greatly improves business success. Having multiple lead sources can grow your business and reduce your risk. Compare these two partnerships.

Current Company ABC

• Compensation structure
• Technology platform
• CRM
• Compliance support
• Processing support
• Recruiting opportunities
• Marketing support
• Training
• Company culture
• Branch autonomy

Proposed Company XYZ

• Compensation structure
• Technology platform
• CRM
• Compliance support
• Processing support
• Recruiting opportunities
• Marketing support
• Training
• Company culture
• Branch autonomy

Remember, total value is about more than just pay.

Step 5: Review Branch Economics

Many branch managers focus on income but don’t always understand all the costs involved.

Items include:

• Payroll
• Payroll taxes
• Processing expenses
• Credit reports
• Technology costs
• CRM expenses
• Marketing expenses
• Recruiting expenses
• Licensing expenses
• Office expenses
• Insurance
• Compliance costs
• Professional services

Be sure to make sure to list and track every expense.

Profit and Loss Analysis.

Review the current branch P&L.

• Gross revenue
• Direct costs
• Fixed expenses
• Variable expenses
• Net operating income
• Profit margin
• Cost per loan
• Revenue per loan

This review can show you how your branch can make more profit without producing more.

Step 7: Create a Pro-Forma Financial Model

You can create many scenarios to predict how profitable a new branch setup might be. For example:

• 5 loans per month
• 10 loans per month
• 20 loans per month
• 50 loans per month

Test these models at different production levels and see how the results differ.

The goal is to determine whether the new setup is more profitable and can grow over time.

Step 8: Review Compensation Structures

Compensation is one element of the business model. Consider the following:

• MLO compensation
• Branch manager compensation
• Compensation for recruiters
• Revenue and profit sharing
• Bonuses and benefits
• Employer payroll taxes
• Independent Contractor vs. W-2

Sometimes, paying more can actually help you make more profit.

Step 9: Evaluate the Long-Term Vision

Look at how profitable the model will be over time. Some setups may seem good now but fail later.

Consider the following questions:

• Is it scalable?
• Can it recruit talent?
• Can it retain talent?
• Can it weather a downturn in the market?
• Can it expand geographically?
• Can it improve profitability?
• Can it increase long-term enterprise value?

A good business model should support both your short-term and long-term goals.

Step 10: Create a good business plan should support both your short-term and long-term goals in an objective manner.

• Determine the risks
• Determine the opportunities
• Create a plan with goals.
• Create deadlines

When making decisions, focus on the facts, not just the pay.

The best way to move forward is to use a well-rounded approach, not just one model for profitability, growth, or pay. Brokerages that succeed usually focus on partnerships and lead generation, which are proven ways to grow and add long-term value.

Questions for Discussion

• What do you look for in a mortgage branch due diligence process?
• What financial indicators do you believe carry the most significance?
• Has changing your workplace ever revealed hidden costs?
• When looking at new prospects, what blunders should the mortgage industry avoid?
• What tools and resources do you recommend for due diligence?

• This reply was modified 1 week, 5 days ago by  Gustan Cho.