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ComplyIO Testing Parameters

ComplyIO Software uses the following testing parameters when testing a loan

 

1. ComplyIO Software uses the following testing parameters when testing a loan

All States

Consummation is the same as the Closing Date

All States

Timing tests are based on the time zone of the corporate office

All States

No Non-English forms

All States

Application Taken Date is the same for each borrower on the loan

All States

All borrowers are natural persons

All States

Client assumes liability for the accuracy of the Application Taken Date.

All States

All ARM loans are assumed to be fully amortizing unless specified otherwise using an identified program feature.

All States

All Open-Ended Mortgages are considered HELOCs. If you have an open-ended product that is not a HELOC please contact us.

All States

The following date substitutions are identified in the ComplyIO report. Client takes responsibility to review any and all messages regarding date substitutions. These date substitutions are necessary in order to allow ComplyIO to run the required tests.


If “Closed” is not available, CIO will substitute the dates using the following waterfall:

Scheduled Closing

Closing Estimate

Current Date (date CIO test is run)


CIO will substitute the Current Date, if the following dates are not available:

Application Taken

Lock Date

LE Delivered


When a substitution is used, it will apply to all testing including, timing tests; the report will be labelled an "Interim Report." A Final Closing Date is required to get a "Final Report."

This list is not exhaustive as we continue to build out the state rules.

All States

When determining a discount or premium rate for an adjustable rate loan, CIO will round the fully index rate based on the data provided by the loan origination software or other Source System.

All States

Affiliate is defined by 12 CFR 1026.32(b)(5). Affiliate means any company that controls, is controlled by, or is under common control with another company, as set forth in the Bank Holding Company Act of 1956 (12 U.S.C. 1841 et seq.).

All States

No Insurance Sales Related Docs

All States

No Coverage if Lender is also selling insurance

All States

Any fee type not identified in LendingPad will be included in calculations as "other."

All States

Trigger dates (Application date, Lock date) will determine index values. When these trigger dates have not been input, CIO will use the current date until the trigger date is available.

All States

Following Closing, CIO will use the index rate lock as of the Closing.

All States

'Construction Only' loans are for the purpose of the initial construction of a dwelling

All States

Construction to Permanent' loans are for the purpose of the initial construction of a dwelling

All States

All Credit Insurance fee Premiums are voluntary and not a requirement of the loan approval

All States

Balloon Tests are tracked by user designation of "Balloon Feature." Actual payment amounts are not considered when identifying a Balloon Loan

All States

LendingPad does not capture whether or not a fee is financed; therefore, a fee being financed cannot currently be considered in CIO testing.

All States

All Prepayment Penalty Plans identified in LendingPad are used in testing (see below). If you have a product with a prepayment plan that is not identified in LendingPad, please contact us.

All States

It is assumed that each company is operating under a single company license

All States

FNMA, FHLMC, FHA, and VA reviews are limited to the tests included in the Knowledge Base Article titled: "FNMA, FHLMC, FHA, and VA Reviews"

Florida

No loans under Small Loan Act

Alabama

No loans under Small Loan Act

All States

NMLS Information is as of the most recent upload to CIO from NMLS. It does not reflect any previous NMLS license status. NMLS information will not reflect any changes between the time of the previous upload and the present time.

All States

The only financed fees CIO supports are for FHA, VA, and USDA

All States

All credit insurance types fall into the following categories: Disability, Life, Property, Unemployment, DebtCancellation, and DebtSuspension. If you have a product that does not fit into these categories, please contact your account executive.

   
 

2. Loan Types Not Supported By CIO

All States

No USDA Direct Loans (Section 502)

All States

No Assumption Transaction Loan Types

All States

No Timeshares

All States

No Reverse Mortgage

All States

No Growing Equity Mortgage (GEM) Loans

All States

No Graduated Payment Mortgage (GPM) Loans

All States

No Public and Indian Housing Loans

All States

No Local Finance Agency Loans (ComplyIO does not include compliance with State or Local Finance Agency laws, statutes, and regulations.)

All States

No State Finance Agency Loans (ComplyIO does not include compliance with State Finance Agency laws, statutes, and regulations.)

All States

No "other" loans from MISMO

All States

No Loan Modifications

All States

No "Seasonal" Balloon Loan Exceptions § 1026.32(d)(1)(ii)(A)

All States

No Public & Indian Housing

All States

No Boats

All States

No Mobile Homes without HUD Certification Sticker

All States

No Bridge Loans without special exception from LendingPad

All States

No Servicing

All States

No loans for purposes other than personal, family, or household use

All States

No Loans with more than four (4) units

All States

No Relocation Loans

All States

No Condo Hotel Loans

USDA

No USDA Loans

FHA

No Title 1 Loans

VA

Loans made directly by the VA (Direct or Assumption Loans)

CA

No Shared Appreciation Loans

FL

CIO excludes Savings Banks until further notice.

NC

North Carolina Consumer Finance Act. CIO is not currently covering loans that are originated by an affiliate located in the same office as the entity licensed under this Act and originating a loan under this Act's jurisdiction. CIO only covers loans originated by entities licensed as a Mortgage Lender, Mortgage Broker, or registered Depository entity originating a loan originated under this Act.

NY

No Loans for unattached manufactured housing

NY

The amount of the interest rate reduction purchased by the discount points is reasonably consistent with established industry norms and practices for secondary mortgage market transactions.

OH

Calculations are made using Lock Date in place of Rate Set Date as defined in 12 CFR 1026

TN

No S&L or Savings Banks

TX

No Wrap-Around Mortgage

UT

No Utah consumer credit code

   
 

3. Limited Investment Loan Testing

All States

Investment loans are tested against FNMA and FHLMC tests indicated above

   
 

4. CIO Docs

All States

CIO Docs does not provide "Agreements"

   
 

5. Loan Limit

All States

No First Lien loans below $50,000, except Florida

All States

No Junior Lien Loans below $25,000, except Florida

   
 

6. The Only Prepayment Penalty Plans Supported by CIO are as follows:

PPID

PPDescription

PPID

12 Months of 6 Months Interest of 80 Percent Original Balance

PPID

12 Periods of 6 Months Interest of Original Balance

PPID

2-1 on Original Balance and Full Pay

PPID

2-1 Percent of Prepaid Principal

PPID

2-2-1 of Current Principal Balance

PPID

2-2-1 of Original Principal Balance

PPID

24 Months of 6 Months Interest of 80 Percent Original Balance

PPID

24 Periods at 2 Percent of Prepaid Principal

PPID

24 Periods of 6 Months Interest of Original Balance

PPID

3-2-1 at Percent of Original Balance

PPID

3-2-1 Percent of UPB

PPID

36 Months of 6 Months Interest of 80 Percent Original Balance

PPID

36 Periods at 6 Months Interest UPB

PPID

36 Periods of 6 Months Interest of Avg Balance

PPID

36 Periods of 6 Months Interest of Avg UPB for Period

PPID

36 Periods of 6 Months Interest of Original Balance

PPID

48 Months of 6 Months Interest of 80 Percent Original Balance

PPID

5 Percent of Prepaid Principal

PPID

5-4-3 Percent of UPB

PPID

5-4-3-2-1 Percent of UPB

PPID

5-5 Percent of Prepaid Principal

PPID

5-5-5 Percent of Prepaid Principal

PPID

5-5-5-5 Percent of Prepaid Principal

PPID

5-5-5-5-5 Percent of Prepaid Principal

PPID

60 Months of 6 Months Interest of 80 Percent Original Balance

PPID

60 Periods of 6 Months Interest at Original Balance and Accrual Rate

PPID

60 Periods of 6 Months Interest of Original Balance