The occurrence of FHA loans receiving an FHA TOTAL Scorecard approval and subsequently having the loan denied once it hits the underwriter’s desk is happening more and more. It’s a reality the field must acknowledge and from what I have seen, the good originators have taken note and have adjusted their game accordingly.
However, before adjusting your game, you must understand the reasoning behind why this is happening and will continue to occur in the future. Quite frankly, it is at this execution juncture point, that the details and actions of originators are what separate the superstars from the rest of the pack.
The Reason
While the technical reason behind this shift has been in place for years, the enforcement has not until recently. In a nutshell, HUD has stepped up their post endorsement technical reviews and NOT letting lenders insure loans they allowed in the past. In short, previously they were letting lenders slide and NOW they are NOT!
HUD has from the beginning made it clear to lenders that regardless of the Automated Underwriting System (AUS) findings, it was still the lenders responsibility to ensure the data input to TOTAL Scorecard was accurate as required per FHA guidelines AND also demonstrate if there are factors that could not be determined, measured or quantified by the TOTAL Scorecard decision that would invalidate the initial approval decision.
An example of such, is multiple and excessive Non-Sufficient-Funds (NFS) on the borrowers bank checking statements. Since FHA TOTAL Scorecard cannot measure nor account for NSF’s in their decision (recommendation), they defer this determination of layered risk analysis to their Direct Endorsement (DE) lenders to establish if unaccounted layers of risk invalidate a TOTAL Scorecard approval/recommendation.
It is important to note a point HUD stresses to lenders on the back-end…the TOTAL Scorecard decision is ONLY a recommendation and it is the responsibility of the DE lender to determine the accuracy of the approve recommendation. Thus, “due diligence” is the ambiguous “standard” DE lenders are being held to in regards to TOTAL Scorecard approvals. What this means to originators, Realtors and builders is the “approval” received from TOTAL Scorecard (Fannie and Read more