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Volume 25 - Number 15

July 21, 2014

CFPB ‘Mini-Corr’ Guidance Leaves Some Big Questions Unanswered

The CFPB recently issued new guidance that warns mortgage brokers to avoid acting as mini-correspondents in an attempt to side-step consumer protection laws and disclose how much money they make on a transaction. The bureau is concerned that some mortgage brokers may be setting up arrangements with investors in which the broker claims to be a ďmini-correspondent lender,Ē when in fact the broker is still essentially just facilitating a transaction between a borrower and a lender. In its new guidance, the agency sets out some of the questions the CFPB may consider in evaluating mortgage transactions involving mini-correspondent lenders in order to understand their true nature. This evaluation involves examining how the mini-correspondent lender is structured and operating. Among the ...

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With originations expected to drop in 2018, will your shop turn to non-QM/non-prime mortgage products as a way to bolster volumes?

Yes, definitely. We’re planning a launch.


No. It’s still difficult compliance/regulatory-wise.


Maybe. It’s under consideration.


Not now. But things could change as 2018 progresses.