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Basic ComplyIO troubleshooting

Please see the below notes for loan file setup. There is also a PDF guide attached to this KB.

CIO Training

CIO E-Training

Please navigate to the Loan Additional > Compliance information section 

 

Qualified Mortgage Section

  • The Qualified Mortgage drop-down must be the correct option
    • Agency QM - Government loan 
    • Certain Creditor Balloon payment QM will only apply to a small percentage of use cases. Check with your manager or compliance department regarding the loan scenario of the file.
    • General/Standard QM - Fannie/Freddie loans and Non-QM
    • Seasoned QM - This is not applicable as the CIO does not currently run for post-closing and servicing.
    • Small creditor portfolio QM—Your institution would have to be designated as a small creditor. Check with your system admin or internal compliance department to see if this is applicable. 
  • Please Choose the applicable presumption of compliance. 
  • Could you go ahead and go to Non-QM toggle if applicable? 

 

Ability to Repay Section

  • Exempt—If exempt is chosen, another field will be available, and the exemption type must be chosen. (For investment loans, mark exempt, and the credit purpose exemption toggle should be on.)
  • General - when the loan is a Non-QM loan 
  • Qualified Mortgage - Conventional and Government loan scenarios.
  • To have discount points bonafide please toggle the BonaFide discount toggle in the Loan Additional> Compliance Information section > Ability to Repay section

 

Fees

  • CIO will run off the of the Fee Type NOT the name of the fee.
  • Using the fee type of "other" is not recommended as it will be included in CIO's report
  • To streamline the process LenderFBO designation is recommended for default fees such as USDA guarantee fee. This can be set as default in the Settings > Fee and escrow type > Paid To settings.
  • Loan level - Paid to third party and LenderFBO will be removed from any fee test thresholds.