4/02/2020

New Mortgage Restrictions Tighter hands


Restriction: Non-Liquid Assets
Statement from current quarter required

Restriction: Self Employed Qualifying Income
The following is required for Self Employed or 1099 income:
·         Reduce qualifying income by 25% OR
·         12 months reserves required

Restriction: Future Income
Not Permitted
·         If borrower qualifies without future income the loan may proceed

Restriction: Manual Underwrite
Ineligible


Restriction: Age of Documents
Credit, income and asset documentation must be ≤ 60 days prior to note date

Guideline Update | FHA
Retail            Consumer Direct         Correspondent            Wholesale


Effective with locks on or after April 2, 2020

Restriction: Min FICO

WHOLESALE AND CORRESPONDENT
Transaction Type
FICO
Purchase, Rate & Term, Streamline, Cash Out
640
Manual Underwrites
660
203K Limited and Standard
640
203K Limited and Standard Manual Underwrites
660
Note: No Extensions or Relocks permitted

Effective with note dates on or after April 6, 2020
Restriction: DTI and Reserves Requirement

DTI
Required Reserves
>45% and <50%
2 months PITIA liquid reserves
≥50%
6 months PITIA Liquid reserves

Restriction: Transactions with Gift Funds
Max DTI 45%

Restriction: Manual Underwrite Reserve Requirements
2 months PITIA liquid reserves

Restriction: First Time Home Buyer
If living rent free, 6 months PITIA liquid reserves required

Restriction: Non-Liquid Assets
Statement from current quarter required

Restriction: Self Employed Qualifying Income
The following is required for Self Employed or 1099 income:
·         Reduce qualifying income by 25%, or
·         12 months reserves required

Restriction: Future/Expected Income
Not Permitted
·         Loans with future income must cease at this time
o   If borrower qualifies without future income the loan may proceed

Restriction: Age of Documents
Credit, income and asset documentation must be ≤ 60 days prior to note date

Guideline Update | USDA
Retail            Consumer Direct         Correspondent            Wholesale


Effective with locks on or after April 2, 2020

Restriction: Min FICO

WHOLESALE AND CORRESPONDENT DIRECT
TRANSACTION TYPE
MIN FICO
Purchase, Rate & Term, Streamline Assist
640
Manual Underwrite
660
Note: No Extensions or Relocks permitted

Effective with note dates on or after April 6, 2020
Restriction: DTI and Reserves Requirement

DTI
Required Reserves
>45% and <50%
2 months PITIA liquid reserves
≥50%
6 months PITIA Liquid reserves

Restriction: Transactions with Gift Funds
Max DTI 45%

Restriction: Manual Underwrite Reserve Requirements
2 months PITIA liquid reserves

Restriction: First Time Home Buyer
If living rent free, 6 months PITIA liquid reserves required

Restriction: Non-Liquid Assets
Statement from current quarter required

Restriction: Self Employed Qualifying Income
The following is required for Self Employed or 1099 income:
·         Reduce qualifying income by 25%, or
·         12 months reserves required

Restriction: Future/Expected Income
Not Permitted
·         Loans with future income must cease at this time
o   If borrower qualifies without future income the loan may proceed

Restriction: Age of Documents
Credit, income and asset documentation must be ≤ 60 days prior to note date


Guideline Update | VA
Retail            Consumer Direct         Correspondent            Wholesale


Effective with locks on or after April 2, 2020

Restriction: Min FICO

WHOLESALE AND CORRESPONDENT
Transaction Type
FICO
Conforming Loan Amount
640
Manual Underwrite
660

Note: No Extensions or Relocks permitted

Restriction: IRRRL – Collateral Value

WHOLESALE AND CORRESPONDENT
The following must be provided to support value:
·         AVM or Drive by Appraisal

Note: No Extensions or Relocks permitted

Effective with note dates on or after April 6, 2020
Restriction: DTI and Reserves Requirement

DTI
Required Reserves
>45% and <50%
2 months PITIA liquid reserves
≥50%
6 months PITIA Liquid reserves

Restriction: Transactions with Gift Funds
Max DTI 45%

Restriction: Manual Underwrite Reserve Requirements
2 months PITIA liquid reserves

Restriction: First Time Home Buyer
If living rent free, 6 months PITIA liquid reserves required

Restriction: Non-Liquid Assets
Statement from current quarter required

Restriction: Self Employed Qualifying Income
The following is required for Self Employed or 1099 income:
·         Reduce qualifying income by 25%, or
·         12 months reserves required

Restriction: Future/Expected Income
Not Permitted
·         Loans with future income must cease at this time
o   If borrower qualifies without future income the loan may proceed

Restriction: Age of Documents
Credit, income and asset documentation must be ≤ 60 days prior to note date

 IN SUMMARY
SELF EMPLOYED GET A BIG INCOME HAIRCUT
NO more rental income to offset
More cash reserves
Lower debt to Income RATIOS
MUCH HIGHER FICO SCOREs

California we are in for a difficult ride

















Age of Documentation
Age of documents are being modified to two months (60) days from four months (120 days) for most income and asset documentation.  If an asset account is reported on a quarterly basis, the most recently issued quarterly statement is required.

Third Party Employment verification will now require the vendor’s database to be no more than 60 days old as of the note date.

Standard age of document requirements will remain for Military Income documented using a Leave and Earnings Statement, Social Security, Retirement Income, Long Term Disability, Mortgage Credit Certificates, Public Assistance, Foster Care, or Royalty Payments.

Due to the federal income tax filing extension granted through July 15, 2020, the following documentation requirements are being eliminated:
  • A copy of the IRS Form 4868 (Application for Automatic Extension of Time to File U.S. Individual Tax Return), AND
  • IRS Form 4506-T (Request for Transcript of Tax Return) transcript to confirm “No Transcript Available” for the 2019 tax year.

All other requirements in regards to Allowable Age of Credit Documents and Federal Income Tax Returns continue to apply.

Verification of Self Employment
When using self-employment income to qualify a borrower, the existence of the borrower’s business must be verified within 120 calendar days prior to the note date.  Due to latency in system updates or re-certifications using annual licenses, certifications, or government systems of record, additional steps must be taken to confirm that the borrower’s business is open and operating.   This must be confirmed within 10 business days of the note date.

Below are examples of methods that may be used to confirm the borrower’s business is currently operating:

  • Evidence of current work (executed contracts or signed invoices that indicate the business is operating on the day self-employment is verified);
  • Evidence of current business receipts within 10 days of the note date (payment for services performed);
  • Certification the business is open and operating (confirmed through a phone call or other means); OR
  • Business website demonstrating activity supporting current business operations (timely appointment for estimates or service can be scheduled).
  • They may ask for last two weeks business deposits or letters explaining how operations is continuing
  • keep in mind in California they have to be an essential business to be out and about normal


Market Based Assets
Stocks, Stock Options, and Mutual Funds -
In light of current market volatility, the following updates are being made when the borrower is using stocks, stock options, or mutual funds for assets:
  • When used for down payment or closing costs, evidence of the borrower’s actual receipt of funds realized from the sale or liquidation must be documented in all cases.
  • When used for reserves, only 70% of the value of the asset must be considered, and liquidation is not required.