Broker QC Plan - Wholesalers

Several wholesalers have been reviewing our quality control plan for brokers. It is important for brokers to note that many of these reviewers don't actually read an entire plan, so that if something doesn't jump off the page at them, they may mark your plan as deficient. 

The most important thing to remember is that you want your plan to reflect PROCEDURES about how you work to catch ANY possible error. This is completely different from writing a POLICY, which simply states that you will look for various elements.  For instance, a recent communication showed:

The Pre-Funding Quality Control Requirements are:
·         Quality Control is Conducted by someone other than party to loan originations - Page 22
·         The Borrower Social Security number is re-verified on all loans - Page 14
·         The Income calculations and supporting documentation is reviewed - Page 13
·         Verbal verifications of employment are conducted - Page 20
·         Assets needed to close or meet reserve requirements are reviewed - Page 15  
·         Appraisal or other property valuation is reviewed - Page 16
·         Documentation is reviewed to assure adequate mortgage insurance coverage - Page 12
·         Review loan to determine automated underwriting info is accurate - Page 18
·         Liabilities between 1003 and credit report are reconciled - Page 12.1

The page numbers show where you can locate the requirement as it is addressed as part of the much more extensive documentation review.  

DO NOT write a policy that states that you will simply check for these items, as it opens you up for liability for missing other elements associated with the items requested, that have not been requested to be stated in policy in writing.