KNOW BEFORE YOU OWE TILA-RESPA INTEGRATED DISCLOSURES. FNC Enterprise Vendor Management Origination, Servicing, Lending/Marketing and Capital Markets

Transcription

1 KNOW BEFORE YOU OWE TILA-RESPA INTEGRATED DISCLOSURES FNC Enterprise Vendor Management Origination, Servicing, Lending/Marketing and Capital Markets 2015

2 Know Before You Owe Services We Offer 3 Easy Steps Connect, Collaborate, and Disclose 1. Our Vendor Management Module solves 3 rd party vendor management and oversight of approved vendors A. We enable lenders/creditors to approve vendors by identifying, vetting and documenting known and unknown vendors. Our Vendor Management Module vets, documents and validates vendors Once validated, lenders issue credentials to vetted vendors enabling secure connectivity and collaboration B. Once credentialed, we maintain documentation, report and monitor your vendors on an on-going basis. Vendors are credentialed in our Collateral Management System and FNC Ports (AppraisalPort, TitlePort, InspectionPort, and LoanPort). Vendors can be terminated easily with supporting documentation. 2. LoanPort enables connectivity and collaboration between the lender and vendors Audit logs track all versions 3. myloanport are two consumer apps for disclosure and acknowledgement (Apple and Android versions) 2

3 How the Pieces/Parts Fit Vendor Management document vendors; send them documents/receive required documents from vendors; approve, credential and track vendors 2. LoanPort portal for collaboration between lender and vendors; portal for secure communication with all parties and secure disclosure and acknowledgement by the consumer 3. myloanport app for disclosure and acknowledgement by the consumer 4. FNC Connect secure infrastructure pipes for passing credentials, secure communication, and data/documents 5. Developer s API developer s web page for integration, updates and maintenance on FNC Connect 5 3

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5 Vetting The Vendor 1. Conducting thorough due diligence (both on-going and ad-hoc vendors) A. Placing vendor on notice via documentation as to creditor expectations B. Obtaining appropriate documentation from vendor covering scope of offerings 2. Requesting and reviewing, policies, procedures, and other materials 3. Contract requirements for compliance and provisions (consequences) for non-compliance 4. Internal controls and monitoring policy, procedures and audit mechanisms 5. Audits and results of non-compliance 5

6 Vendors In The Settlement Process Appraisers and other valuation professionals Vetted in the Vendor Management Module Approved and credentialed in the FNC Collateral Management System Engaged through AppraisalPort Title providers Vetted in the Vendor Management Module Approved and credentialed in the FNC Collateral Management System Engaged through TitlePort Inspection providers Vetted in the Vendor Management Module Approved and credentialed in the FNC Collateral Management System Engaged through InspectionPort Settlement agents Vetted in the Vendor Management Module Approved and credentialed in LoanPort Engaged through LoanPort 6

7 FNC CMS And Ports Enterprise Collateral Information for Origination 7

8 Data and Documents to LoanPort Vendor Management Data Collaboration Disclosure Vendor information & credentials Uniform Closing Dataset Loan Estimate LOS 1. LOS is system of record 2. Settlement agents input coverage, services, data and fees; creditor verifies, approves and issues credentials; 3. All versions of Closing Disclosure issued by LOS 4. All disclosures via app, web page or mail service. 5. All audit logs, changes, and communications kept by LoanPort and retained by FNC or sent to creditor. TRACKING TRACKING TRACKING TRACKING TRACKING PROCESSOR AND/OR CLOSER Feedback, Disputes SETTLEMENT AGENTS On-Going and Ad Hoc Disclosure and Acknowledgement CONSUMER 8

9 Consumer Disclosure And Acknowledgement 1. Web page disclosure and acknowledgement 2. App disclosure and acknowledgement Apple/Safari/iOS Google/Android 3. Use of a mail service Key is getting the consumer to acknowledge disclosure and what to do (follow-up) if they do not acknowledge. Additional notices Flags in the file Workflow discussion 9

10 Authentication Of The Consumer We use two factor authentication think ATM withdrawals Something you know your PIN Something you have your ATM card For TRID Something you know your address Something you have your cell phone and/or ipad or Android equivalent Notices Prominent notice and permission for electronic disclosure Prominent notice and permission for electronic acknowledgement Prominent notice and permission to send text message 10

11 Consumer s Acknowledgement Via Signature Sign three different ways Draw your signature in the drawing pad Upload your signature from a file Sign via the app We turn your phone or ipad/android device into a signing pad You sign with your finger and upload Software captures signature and time/date stamps 11

12 Who Needs What Technologies Creditor Current browser manufacturer supported version of a major browser such as Safari, Internet Explorer, Chrome, Firefox Connectivity to the internet Ideal, two-way interface into the creditor s LOS supporting UCD and ULDD Creditor account on LoanPort Settlement Agent Current browser manufacturer supported version of a major browser such as Safari, Internet Explorer, Chrome, Firefox Connectivity to the internet Settlement agent account on LoanPort Valid credentials issued by the creditor Consumer For mobile phone app iphone 4S or higher/android equivalent/ipad/tablet with connectivity to the internet For web signing manufacturer supported version of a major browser such as Safari, Internet Explorer, Chrome, Firefox For mailbox delivery a valid USPS address Valid credentials issued by the creditor 12

13 TRID and Appraisal Fees After 10/3/2015 There are shopping items There are non-shopping items The appraisal is a non-shopping item The quoted fee must be correct We will help you quote the applicant the correct fee Webinar is this Thursday 13

14 Thank you for your time. For further information, please contact: Kelley Hunsberger Marketing Coordinator