Loan Repurchase and Rescission Policy Manual
Loan repurchase or rescission requests to lenders occur when a loan is not originated or serviced in accordance with representations or warranties required in contract covenants or seller/servicer guidelines. The request may be fueled by demands from private investors, mortgage insurers, or financial guarantors. These companies are looking to limit their own losses from defaulted or fraudulent mortgages. Lenders must establish an effective process for reviewing repurchase requests, and if necessary, issuing rebuttals or processing repurchases.
The AllRegs Loan Repurchase and Rescission Policy Manual provides guidance from agencies, mortgage insurance companies and warehouse lenders and includes transactional review and rebuttal considerations.
The manual features the following benefits:
- Supports strong operational preparedness
- Establishes staff training requirements
- Defines roles and responsibilities
- Helps meet regulatory and internal compliance requirements
- Allows policy revisions to fit your business model
- Delivered via email within one business day
Maintenance: Receive regular and ongoing industry updates to keep your policy within regulatory requirements.
Publishing: Publish your manual, including your company procedures, in AllRegs Online to complete your policy manual solution.
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|1.1||Goals and Objectives||Mandatory Review||Include the point of view or culture of your organization in this section, if applicable.|
|1.2||Required Review||Mandatory Review||Be sure this accurately reflects your company’s annual policy review process.|
|2.1||Quality Control Program||Optional Enhancement||Consider revising this to reflect and reference the actual quality control program in place.|
|2.2||Internal Controls||Mandatory Review||Include or reference related procedures in this section.|
|3||Staff and Training||Mandatory Review||Include the means by which your organization provides and tracks required training.|
|4.5||Mortgage Insurance Companies||Recommended Best Practice||Ensure your organization is aware of and has applied new rescission relief principles effective March 31, 2019.|
|5||Transactional Considerations||Mandatory Review||Timeframes and tolerances reflected within this section are general industry recommendations. You should update this, as required, to reflect your organization’s operations.|
|7||Repurchase Requests and Rebuttal Process||Recommended Best Practice||Providing a high level overview of the rebuttal process by topic, this section offers many opportunities for expansion with your specific procedures. Consider detailing steps to be followed or appending checklists that aid in the process.|
|9||Loss Mitigation, Valuation and Indemnity||Optional Enhancement||It would be appropriate in this section to cross-reference to your existing Loss Mitigation Policy.|
|10||Servicing||Optional Enhancement||Seller servicers may wish to reference their existing Servicing policy here.|