1 PUBLIC DISCLOSURE FEBRUARY 12, 2015 MORTGAGE LENDER COMMUNITY INVESTMENT PERFORMANCE EVALUATION NE MOVES MORTGAGE, LLC MC SECOND AVENUE, 3RD FLOOR WALTHAM MA DIVISION OF BANKS 1000 WASHINGTON STREET BOSTON MA NOTE: This evaluation is not, nor should it be construed as, an assessment of the financial condition of this mortgage lender. The rating assigned to this mortgage lender does not represent an analysis, conclusion or opinion of the Division of Banks concerning the safety and soundness of this mortgage lender.
2 GENERAL INFORMATION Massachusetts General Laws chapter 255E, section 8 and the Division of Banks (Division) regulation 209 CMR 54.00, CRA for Mortgage Lender (CRA), require the Division to use its authority when examining mortgage lenders subject to its supervision who have made 50 or more home mortgage loans in the last calendar year, to assess the mortgage lender s record of helping to meet the mortgage credit needs of the Commonwealth, including low- and moderate-income neighborhoods and individuals, consistent with the safe and sound operation of the mortgage lender. Upon conclusion of such examination, the Division must prepare a written evaluation of the mortgage lender s record of meeting the credit needs of the Commonwealth. This document is an evaluation of the CRA for performance of NE Moves Mortgage, LLC (the Lender or NE Moves) prepared by the Division, the Lender s supervisory agency, as of March 17, SCOPE OF EXAMINATION An onsite evaluation was conducted using examination procedures, as defined by CRA guidelines. A review of the Division s records, as well as the Lender s public CRA file, did not reveal any complaints. The CRA examination included a comprehensive review and analysis, as applicable, of NE Moves : (a) origination of loans and other efforts to assist low and moderate-income residents, without distinction, to be able to acquire or to remain in affordable housing at rates and terms that are reasonable considering the mortgage lender's history with similarly situated borrowers, the availability of mortgage loan products suitable for such borrowers, and consistency with safe and sound business practices; (b) origination of loans that show an undue concentration and a systematic pattern of lending resulting in the loss of affordable housing units; (c) efforts working with delinquent residential mortgage customers to facilitate a resolution of the delinquency; and (d) other efforts, including public notice of the scheduling of examinations and the right of interested parties to submit written comments relative to any such examination to the Commissioner, as, in the judgment of the Commissioner, reasonably bear upon the extent to which a mortgage lender is complying with the requirements of fair lending laws and helping to meet the mortgage loan credit needs of communities in the Commonwealth. CRA examination procedures were used to evaluate NE Moves community investment performance. These procedures utilize two performance tests: the Lending Test and the Service Test. This evaluation considered NE Moves lending and community development activities for the period of January 2013 through December The data and applicable timeframes for the Lending Test and the Service Test are discussed below. The Lending Test evaluates the mortgage lender s community investment performance pursuant to the following five criteria: geographic distribution of loans, lending to borrowers of different incomes, innovative and flexible lending practices, fair lending, and loss of affordable housing.
3 Home mortgage lending for 2013 and 2014 is presented in the geographic distribution, lending to borrowers of different incomes and the Minority Application Flow tables. Comparative analysis of the Lender s lending performance for the year of 2013 is provided because it is the most recent year for which aggregate HMDA lending data is available. The aggregate lending data is used for comparison purposes within the evaluation and is a measure of loan demand. It includes lending information from all HMDA reporting mortgage lenders which originated loans in the Commonwealth of Massachusetts. In addition to gathering and evaluating statistical information relative to a mortgage lender s loan volume, the CRA examination also reflects an in depth review of the entity s mortgage lending using qualitative analysis, which includes, but is not limited to: an assessment of the suitability and sustainability of the mortgage lender s loan products by reviewing the mortgage lender s internally maintained records of delinquencies and defaults as well as information publicly available through the Federal Reserve Banks and through local Registries of Deeds and through other sources available to the examination team. The examination included inspection of individual loan files for review of compliance with consumer protection provisions and scrutiny of these files for the occurrence of disparate treatment based on a prohibited basis. The Service Test evaluates the mortgage lender s record of helping to meet the mortgage credit needs by analyzing the availability and effectiveness of a mortgage lender s systems for delivering mortgage loan products, the extent and innovativeness of its community development services, and, if applicable, loss mitigation services to modify loans and/or efforts to keep delinquent home borrowers in their homes.
4 MORTGAGE LENDER S CRA RATING: This mortgage lender is rated Satisfactory. The geographic distribution of the Lender s loans reflects adequate dispersion in low and moderate-income census tracts, as it is reflective of the distribution of owner occupied housing in those census tracts. Given the demographics of Massachusetts, the loan distribution to borrowers reflects, a reasonable record of serving the credit needs among individuals of different income levels, including low and moderate-income levels. NE Moves offers a variety of flexible lending products, which are provided in a safe and sound manner to address the credit needs of low and moderate-income individuals. Fair lending policies and practices are considered reasonable. The Lender is involved in several Community Development Services and provides Qualified Investments to support home ownership initiatives within the Commonwealth.
5 PERFORMANCE CONTEXT Description of Mortgage Lender NE Moves is the successor to Property Trust Corporation, which was incorporated in Massachusetts in After changing its name to DeWolfe New England Mortgage Services Inc. in 1988, the entity was granted a mortgage lender and mortgage broker license by the Division in After reorganizing several more times, the Lender was established under its current name in NE Moves main office is located at 52 Second Street in Waltham. The Lender has sixty-eight licensed locations at Colwell Banker Residential Brokerage offices located throughout Massachusetts. These locations are available to the Lender s loan officers but do not necessarily have any NE Moves personnel present at any given time. In addition to Massachusetts, the company is licensed to conduct business in Connecticut, Rhode Island, New Hampshire, and Maine. NE Moves offers a variety of mortgage loan products to meet the needs of the Commonwealth s borrowers. NE Moves is an approved lender for the Federal Housing Administration and offers a selection of MassHousing products. All underwriting and major functions in the loan process are done at NE Moves main office. Approved loans are funded through established warehouse lines of credit. NE Moves business development relies primarily on referrals and repeat customers. Originated loans are closed in Lender s name and sold immediately to secondary market investors, with servicing rights released. Demographic Information The CRA regulation requires mortgage lenders to be evaluated on their performance within the Commonwealth of Massachusetts. Demographic data is provided below to offer contextual overviews of economic climate along with housing and population characteristics for the Commonwealth of Massachusetts. Demographic Characteristics 2010 CENSUS DEMOGRAPHIC INFORMATION Amount Low % Moderate % Middle % Upper % Geographies (Census Tracts) 1, Population by Geography 6,547, Owner-Occupied Housing by Geography 1,608, Family Distribution by Income Level 1,600, Distribution of Low and Moderate Income Families Throughout AA Geographies 592, Median Family Income $86,272 Median Housing Value 373,206 Households Below Poverty Level N/A % 11.1% Unemployment Rate 5.1* 2013 HUD Adjusted Median Family Income Source: 2010 US Census *as of 01/31/2015 $84, HUD Adjusted Median Family Income $83,495
6 Based on the 2010 Census, the Commonwealth s population stood at 6.55 million people with a total of 2.79 million housing units. Of the total housing units, 1.61 million or 57.7 percent are owner-occupied, 904,078 or 32.5 percent are rental-occupied, and 9.8 percent are vacant units. According to the 2010 Census there are 2.51 million households in the Commonwealth with a median household income of $69,101. Over 39 percent of the households are now classified as low and moderate-income. In addition, over 11 percent of the total number of households are living below the poverty level. Individuals in these categories may find it challenging to qualify for traditional mortgage loan products. Households classified as families totaled slightly over 1.60 million. Of all family households, 19.2 percent were low-income, 17.8 percent were moderate-income, 24.4 percent were middleincome, and 38.6 percent were upper-income. The median family income according to the 2010 census was $86,272. The Housing and Urban Development (HUD) adjusted median family income is $84,208 in 2013 and $83,495 in The adjusted median family income is updated yearly and takes into account inflation and other economic factors. The Commonwealth of Massachusetts contained 1,474 Census tracts. Of these, 160 or 10.8 percent are low-income; 295 or 20.0 percent are moderate-income; 600 or 40.7 percent are middle-income; 399 or 27.1 percent are upper-income; and 20 or 1.4 percent are NA or have no income designation. The tracts with no income designation are located in areas that contain no housing units and will not be included in this evaluation since they provide no lending opportunities. These areas are made up of correctional facilities, universities, military installations, and uninhabited locations such as the Boston Harbor Islands. Low-income is defined as individual income that is less than 50 percent of the area median income. Moderate-income is defined as individual income that is at least 50 percent and less than 80 percent of the area median income. Middle-income is defined as individual income that is at least 80 percent and less than 120 percent of the area median income. Upper-income is defined as individual income that is more than 120 percent of the area median income. The median housing value for Massachusetts was $373,206 according to the 2010 Census. The unemployment rate for the Commonwealth of Massachusetts stood at 5.1 percent as of January 2015, which was a decrease from July 2014 when the unemployment rate was at 5.6 percent. Employment rates would tend to affect a borrower s ability to remain current on mortgage loan obligations and also correlates to delinquency and default rates.
7 CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS LENDING TEST NE Moves lending efforts are rated under the five performance criteria: Geographic Distribution, Borrower Characteristics, Innovative or Flexible Lending Practices, Fair Lending Policies and Procedures, and Loss of Affordable Housing. The following information details the data compiled and reviewed, as well as conclusions on the mortgage lending of NE Moves. NE Moves Lending Test performance was determined to be Satisfactory at this time. I. Geographic Distribution The geographic distribution of loans was reviewed to assess how well NE Moves is addressing the credit needs throughout the Commonwealth of Massachusetts low, moderate, middle, and upper-income Census tracts. The following table presents, by number, NE Moves 2013 and 2014 HMDA reportable loans in low, moderate, middle, and upper-income geographies in comparison to the 2013 aggregate lending data (exclusive of NE Moves), as well as the percentage of owner-occupied housing units in each of the Census tract income categories. Census Tract Income Level Distribution of HMDA Loans by Income Level Category of the Census Tract 2013 Total Owner- Occupied Housing Units 2013 Licensee 2013 Aggregate Lending Data 2014 Total Owner- Occupied Housing Units 2014 Licensee % # % % of # % # % Low Moderate Middle Upper N/A Total , , Source: 2013 & 2014 HMDA LAR Data and 2010 U.S. Census Data. As reflected in the above table, of the total 1,809 loans originated in 2013, 14.3 percent were in the low- and moderate-income geographies. The percentages in each category were comparable to the percentage of the area s owner occupied housing units in low- and moderate-income geographies, as well as the aggregate lending data percentages. In 2014, the Lender s overall loan volume decreased, while the percentage of lending in lowand moderate-income census tracts remained steady at 14.4 percent. Overall, the geographic distribution of residential mortgage loans reflects adequate dispersion throughout low and moderate-income census tracts within the Commonwealth.
8 II. Borrower Characteristics The distribution of loans by borrower income levels was reviewed to determine the extent to which the Lender is addressing the credit needs of the Commonwealth s residents. The following table shows NE Moves 2013 and 2014 HMDA-reportable loans to low, moderate, middle, and upper-income borrowers in comparison to the 2013 aggregate data (exclusive of NE Moves), as well as the percentage of total families within the Commonwealth in each respective income group. Distribution of HMDA Loans by Borrower Income Level Median Family Income Level 2013 % of Families 2013 Licensee 2013 Aggregate Lending Data 2014 % of Families 2014 Licensee % # % % of # % # % Low Moderate Middle Upper N/A Total , , Source: 2013 & 2014 HMDA LAR Data and 2010 U.S. Census Data. As shown in the above table, lending to moderate-income borrowers in both 2013 and 2014 was above the percentage of moderate-income families and the performance of the aggregate data. NE Moves lending to low-income borrowers during that same period was considerably below the percentage of low-income families, and slightly below the performance of the aggregate data. It should be noted the high housing costs throughout Massachusetts can restrict the ability of low-income mortgage loan applicants to qualify for residential loans, which rather limits the opportunities to lend to these consumers. Although lending to low- and moderate-income borrowers decreased slightly from 2013 to 2014, the Lender s overall lending performance to these income borrowers remains at a reasonable level.
9 III. Innovative or Flexible Lending Practices NE Moves offers a number of flexible lending products, which are provided in a safe and sound manner to address the credit needs of low- and moderate-income individuals or geographies. NE Moves became a Housing and Urban Development approved non-supervised FHA Loan Correspondent in FHA products provide competitive interest rates, smaller down payments for low and moderate income first time homebuyers and existing homeowners. During 2013 and 2014, NE Moves originated 325 FHA loans totaling $87 million. Of these, 120 loans benefited lowto moderate-income consumers, while 69 loans were originated in low- or moderate-income geographies. NE Moves became Veterans Administration (VA) non-supervised agent in The VA Home Loan Guarantee Program is designed specifically for the unique challenges facing service members and their families. Through VA-approved lenders like NE Moves, the program offers low closing cost, no down payment requirement, and no private mortgage insurance requirement. During 2013 and 2014 NE Moves originated 138 VA loans totaling over $42 million. Of these, 40 loans benefited low to moderate-income consumers, while 18 loans were originated in low or moderate-income geographies. NE Moves is a long-term participant in offering Massachusetts Housing Finance Agency (MassHousing) products. MassHousing is a self-supporting not-for-profit public agency that provides financing for homebuyers and homeowners, and for developers and owners of affordable rental housing. The agency sells bonds to fund its programs, which include the My Community program. This loan program offers loan limits as high as $417,000 with the borrower s income limit up to $110,700, with no down payment required, and a 30 year fixed rate loan. In 2013 and 2014, NE Moves originated 499 MassHousing loans with a total of $126 million in dollar volume.
10 IV. Fair Lending The Division examines a mortgage lender s fair lending policies and procedures pursuant to Regulatory Bulletin The Lender s compliance with the laws relating to discrimination and other illegal credit practices was reviewed, including the Fair Housing Act and the Equal Credit Opportunity Act. The review included, but was not limited to, review of written policies and procedures, interviews with NE Moves personnel, and individual file review. No evidence of disparate treatment was identified. NE Moves has established an adequate record relative to fair lending policies and practices. Fair lending is incorporated in NE Moves company-wide policies and procedures that apply to all personnel. Employees are instructed not to discriminate against loan applicants on a prohibited basis. Mortgage loan officers are required to complete the continuing education program, in line with the NMLS requirements. All staff is also encouraged to participate in on-line courses offered by the parent corporation and various other providers, as well as any required agency specific or investor specific training. In addition, NE Moves conducts informal periodic staff meetings that include a review of the existing HMDA and fair lending guidelines and address any changes to ensure compliance. Senior management is responsible for ensuring the Lender is in compliance with current laws and regulations, and for making necessary changes and updates to policies and procedures. NE Moves has contracted external vendors to conduct monthly reviews and annual audits for compliance with regulatory requirements, including CRA and fair lending. MINORITY APPLICATION FLOW For 2013 and 2014, NE Moves underwrote 3,702 HMDA-reportable mortgage loan applications from within the Commonwealth of Massachusetts. Of these applications, 388 or 10.5 percent were received from racial minority applicants, and 304 or 78.3 percent resulted in originations. During the period, NE Moves received 170 or 4.6 percent of HMDA reportable applications from ethnic groups of Hispanic origin, and 124 or 72.9 percent were originated. This compares to 80.0 percent overall ratio of mortgage loans originated by the Lender in Massachusetts, and the 74.6 percent for the ratio of the aggregate. Demographic information for Massachusetts reveals the total ethnic and racial minority population stood at 23.9 percent of the total population as of the 2010 Census. This segment of the population is comprised of 9.6 percent Hispanic or Latino ethnicities. At 14.3 percent, racial minorities consisted of 6.0 percent Black; 5.3 percent Asian/Pacific Islander; 0.2 percent American Indian/Alaskan Native; and 2.8 percent self-identified as Other Race. Refer to the following table for information on the mortgage lenders minority loan application flow as well as a comparison to aggregate lending data throughout the Commonwealth of Massachusetts. The comparison of this data assists in deriving reasonable expectations for the rate of applications the mortgage lender received from minority applicants.
11 RACE MINORITY APPLICATION FLOW 2013 NE Moves 2013 Aggregate Data 2014 NE Moves # % % of # # % American Indian/ Alaska Native Asian Black/ African American Hawaiian/Pacific Islander or more Minority Joint Race (White/Minority) Total Minority White 1, , Race Not Available Total 2, , ETHNICITY Hispanic or Latino Not Hispanic or Latino 2, , Joint (Hisp-Lat /Not Hisp-Lat) Ethnicity Not Available Total 2, , Source: PCI Corporation CRA Wiz, Data Source: 2000 U.S. Census Data, 2013 & 2014 HMDA Data In both 2013 and 2014, NE Moves racial minority application flow was comparable with the population demographics derived from the census data. The Lender s performance was also generally similar to the aggregate figures. Ethnic minority flow was notably lower than the demographic data, but in line with the performance of the aggregate. V. Loss of Affordable Housing This review concentrated on the suitability and sustainability of mortgage loans originated by NE Moves by taking into account delinquency and default rates of the mortgage lender and those of the overall marketplace. Information provided by the Lender was reviewed as were statistics available on delinquency and default rates for mortgage loans. Additionally, individual mortgage loans could be tracked for their status through local Registries of Deeds and other available sources including public records of foreclosure filings. An extensive review of information and documentation, from both internal and external sources as partially described above, did not reveal lending practices or products that showed an undue concentration or a systematic pattern of lending, including a pattern of early payment defaults, resulting in the loss of affordable housing units. Furthermore, at less than two percent, overall loan delinquency rates were found to be consistent with industry averages.
12 SERVICE TEST The service test evaluates a mortgage lender's record of helping to meet the mortgage credit needs in the Commonwealth by analyzing both the availability and effectiveness of a mortgage lender's systems for delivering mortgage loan products; the extent and innovativeness of its community development services; and loss mitigation services to modify loans or otherwise keep delinquent home loan borrowers in their homes. Community development services must benefit the Commonwealth or a broader regional area that includes the Commonwealth. NE Moves Service Test performance was determined to be Satisfactory at this time. Mortgage Lending Services The Commissioner evaluates the availability and effectiveness of a mortgage lender's systems for delivering mortgage lending services to low and moderate-income geographies and individuals. NE Moves provides an effective delivery of mortgage lender services that are accessible to geographies and individuals of different income levels in the Commonwealth. Customers can apply to NE Moves for a mortgage over the telephone and via the company s website. NE Moves main office is located at 52 Second Street in Waltham and is situated in a upper-income geography. The Lender has sixty-eight licensed locations at Coldwell Banker Residential Brokerage offices located throughout Massachusetts across various income-level geographies. In addition to the flexible lending products referenced above, NE Moves also offers the USDA Rural Housing Program, which is an innovative loan program that provides 100% financing for eligible homebuyers in rural-designated areas. Business development relies primarily on referrals and repeat customers. NE Moves conducts minimal advertising in Massachusetts, usually in conjunction with Coldwell Banker. Between March and October of 2014, the Lender ran a WBZ-Radio housing promotion co-branded with MassHousing. As NE Moves does not routinely service mortgage loans, it would not work directly with delinquent borrowers. Therefore, this review would not include an evaluation of loan mitigation and modification efforts as the Lender would not be accountable for such action. However, as described above, lending practices and products did not show an undue concentration or a systematic pattern of lending resulting in mortgage loans that were not sustainable.
13 Community Development Services A community development service is a service that: (a) has as its primary purpose community development; and (b) is related to the provision of financial services, including technical services The Commissioner evaluates community development services pursuant to the following criteria: (a) the extent to which the mortgage lender provides community development services; and (b) the innovativeness and responsiveness of community development services. NE Moves works closely with MassHousing to provide affordable housing within the Commonwealth. The Lender has been recognized multiple times as a Statewide Top Producer of MassHousing, and in 2013 NE Moves and one of its loan officers were recognized in MassHousing s annual report. In 2014 NE Moves was invited to be one of just ten Massachusetts lenders to work with MassHousing and Fair Mortgage in their attempts to build an additional mortgage program directed specifically to the low and moderate income borrowers. The Lender has committed to participate in this program and is involved in the ongoing discussions. In 2014 NE Moves was one of the first non-bank lenders to be invited to participate in the Massachusetts Homeownership Compact. In 2014 NE Moves was also asked to be one of the first non-bank lenders to participate with the City of Boston on its First Time Homebuyer Program. Qualified Investments For the purposes of this CRA evaluation, a Qualified Investment is a lawful investment, deposit, membership share, or grant, the primary purpose of which is community development. The evaluation considered (1) the number of investments and grants, (2) the extent to which community development opportunities have been made available to the institution, and (3) the responsiveness of the institution s community development grants to the assessment area s needs. NE Moves primary charitable endeavor is to support its partner, Coldwell Banker Residential Brokerage with their annual Spirit of Home fundraiser. NE Moves is one of the primary sponsors and, for each year since 2010, contributes $10, to help sponsor the event. The event raises significant funds for local charities that focus on the homeownership. Recent recipients included: Homes for our Troops, Perkins School for the Blind, The New England Center for the Homeless, and Rosie s Place. Over the past several years, NE Moves also provided financial contributions to The Home for Little Wanders and the Massachusetts Mortgage Bankers Foundation, to support debt management assistance and to improve the quality of affordable housing in the state. Management is encouraged to maintain strong focus and pro-active commitment in community development activities or investments that meet the definition of community development under the CRA regulation throughout the Commonwealth. Other activities may include, but not necessarily limited to: financial literacy education initiatives targeted to low and moderateincome individuals; and foreclosure prevention counseling and/or providing technical assistance to community organizations in a leadership capacity.
14 PERFORMANCE EVALUATION DISCLOSURE GUIDE Massachusetts General Laws Chapter 255E, Section 8, and 209 CMR 54.00, the CRA regulation, requires all mortgage lenders to take the following actions within 30 business days of receipt of the CRA evaluation: 1) Make its most current CRA performance evaluation available to the public. 2) Provide a copy of its current evaluation to the public, upon request. In connection with this, the mortgage lender is authorized to charge a fee which does not exceed the cost of reproduction and mailing (if applicable). The format and content of the mortgage lender s evaluation, as prepared by the Division of Banks, may not be altered or abridged in any manner. The mortgage lender is encouraged to include its response to the evaluation in its CRA public file. The Division of Banks will publish the mortgage lender s Public Disclosure on its website no sooner than 30 days after the issuance of the Public Disclosure.
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