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Q: I have more than one DBA. Should I list all of them here? (pg. 3)

A: Please only list your primary DBA in this section. There is an opportunity to input additional DBAs used for specific states elsewhere in the form. Your primary DBA is the name you will use in our system.


Q: What is my Company Structure? (pg. 3)

A: Your Company Structure refers to the Tax Designation you use on your corporate W-9. If you are an LLC, you need to select if you are elected to be taxed as an S corporation, C corporation, or as a partnership (P). If you are unfamiliar with your tax status, please contact your CPA or tax attorney.


Q: What is a Company TIN? (pg. 3)

A: Your Company TIN, also called an EIN, is your Taxpayer Identification Number issued by the Internal Revenue Service. If you are the sole proprietor you may not have a TIN and may use your Broker of Record's Social Security Number.


Q: What is a State-specific DBA? (pg. 3)

A: Some states require forced trade names and some brokers prefer to use a separate DBA in separate states. Please list all DBAs you use in that state if they are different than your company name or your primary DBA.


Q: What is a Top Preferred Lender? (pg. 4)

A: A Top Preferred Lender is the lender who you send the majority of your production to or who provides you with the highest quality service.


Q: What is the difference between Wholesale Units and Correspondent Units? (pg. 4)

A: Wholesale units are the total number of "Third Party Originated" loans (loans brokered to a lender and funded under the lender's NMLS# with the lender's funds). Correspondent units are the total number of loans which you funded as the credit under your NMLS# with funds from your warehouse line.


Q: Will I be able to change my Lender Compensation Designation in the future? (pg. 4)

A: Yes, we allow our Brokers to periodically change their broker compensation. You can complete a Broker Compensation Change Form after you have been approved.


Q: Will credit be run if SSN and Home Address are provided? (pg. 5)

A: No, we need this information for all background checks, but we do not run a separate credit report. Any credit report information in the background check is a "soft pull". We will not accept a Broker without this information.


Q: What if I don't have any Lender References? (pg. 6)

A: Please provide a Letter of Explanation as to why you have no Lender References. If you are a new brokerage, please provide an explanation of your mortgage broker experience.


Q: What Year to Date (YTD) financials are acceptable? (pg. 9)

A: If you are applying from January through April, we will accept the end of the fiscal year financial statements from the previous year. If you are applying from May through December, we need YTD financials or the financials from the last quarter.


Q: What should be covered in the Quality Control (QC) Plan? (pg. 9)

A: All brokers TPOs providing a quality control plan ensures that the TPO remains within JMAC’s compliance standards. All the quality control plans must, at a minimum, state the following:
  1. The company has documented policies and procedures regarding the origination process that complies with all investor, State and Federal laws including, but not limited to (a) State Regulations and Disclosures, (b) Fair Lending, (c) Real Estate Settlement Procedures, (d) Truth in Lending Act, (e) The Privacy Act, (f) USA Patriot Act, (g) BSA/Anti-money Laundering, and (h) Qualified Mortgage and Ability to Repay.

  2. The company has a process which accurately monitors and updates NMLS registration as required per the SAFE Act.

  3. The company has documented procedures to ensure that loan submissions to lenders are accurate and meet all applicable requirements.

  4. The company ensures that all employees are appraised of all State, Federal, and Lender guidelines and updates.

  5. The company has a process to check and monitor OFAC, Freddie Mac Exclusionary List, GSA, and LPD lists for all new hires and participants in mortgage transactions.

  6. The company defines the percentage of loans reviewed for QC, both pre-funding and post-closing, as well as the responsible party for conducting QC, how exceptions are noted, current TRID compliance, and the procedure(s) used to QC loans.

  7. The company has a process to ensure that the TILA/RESPA Integrated Disclosure Rule is followed.

JMAC only accepts quality control plans that have the TPO’s company name and logo; the company’s address; the NMLS identification numbers of the company and the owner; and a certification statement making the required representations and warranties. JMAC’s requirements validate that the quality control plan belongs to the TPO and the TPO, in good faith, adheres to their quality control plan. If JMAC finds any quality control plan discrepancies or requires corrective action, all appropriate documentation is logged and tracked in our systems.


Q: What should be covered in the Hiring Procedures? (pg. 9)

A: The hiring procedures should include a procedure for checking all employees against the FHFA Suspended Counterparty Program (SCP). The FHFA SCP is a list of counterparties which are not permitted on any loan sold to the GSEs and represent an immediate repurchase by the GSEs. Fannie Mae requires that all wholesale lenders review third party originator’s hiring procedures to insure that the third party originator is reviewing the SCP list prior to hiring employees.

For more information refer to the Fannie Mae Selling Guide: https://www.fanniemae.com/content/guide/selling/a3/3/01.html
and the SCP List:
https://www.fhfa.gov/SupervisionRegulation/LegalDocuments/Pages/SuspendedCounterpartyProgram.aspx


 

Still have questions?

Contact our Broker Approval Department

brokerapproval@jmaclending.com