In compliance review, a few maven failures are LE baseline and CD baseline and final fees showing GFE DTI issues.
The best way is to match fees using a new disclosure for LE and if necessary to CD with valid COC reasons. One way is to exclude recent disclosure from the timeline using Disclosure Tracking History tools and add one manual Disclosure record using ‘+’ icon in Tracking history. Now in disclosure details screen select previous date when LE was issued and not current date and set same date for ‘sent date’, ‘actual received date’ and ‘intent to proceed’ date and now click ‘Reasons’ tab and select ‘change circumstances’ Reason – ‘Reason requested by the consumer’ and ‘change received date’ is same date.
Once you will do this all GFE issues will be gone. If fees variance issue is coming, then in that case just see which fees are in red and if compliance is true means we have to open that fee and check the checkbox ‘impacts apr’ and if compliance is false then uncheck ‘impacts apr’. Red fee will be black and so this issue will be resolved.
Now if ATR/QM issue is coming then in ATR / QM management form – ATR QM eligibility -> ATR QM recommendation – select lock icon and then change ‘Ability to repay loan type’ to ‘Qualified mortgage’ and ‘Qualified mortgage loan type’ to ‘General QM’ and ‘Is loan eligible for safe harbor’ to ‘Yes’.
Now in ATR QM Management form, in the ‘Qualification’ tab ‘Risk assessment’ section select DU and so a DU value will come which you can match in ‘ULDD’ form Fannie mae value.
Now for DTI ratio exceeds 43%
Resolution/Answer:
You have the option to check the ‘Use Price-Based General QM ‘ (Field QM.X383) checkbox on the ATR/QM – Qualification tab under the risk assessment section. In my test environment I was able to clear the fail after the box was checked.
Within your Admin tools-> System Administration-> Policies, If your QM Priced based definition date is after the application date in the loan file, QM.X383 (Use Price-Based General QM) field will be greyed out.
Please review your QM Priced based definition date in your admin tools
RESOLUTION
Go to Admin Tools > Settings Manager > Policies > update the Use Price Based General QM Definition Date to 3-1-2021 > save > ok
Go to Tools > ATR/QM Management > Qualification Tab > Risk Assessment Section > now FIELD ID QM.X383 (Use Price Based-General QM) will by un grayed out > Check the box > Re Run Mavent to generate your expected result.
