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-
- The following is a list of "Red Flags" in a loan package which may alert
- a mortgage underwriter to possible Fraud or Misrepresentations. It
- should be emphasized the presence of one or more of these items is not
- necessarily indicative of Fraud; however, they should alert the
- underwriter to further review and document the file. These items may be
- perfectly legitimate when viewed separately, but when taken as a whole,
- a pattern may emerge. In reviewing any loan file, the underwriter
- should constantly ask the following questions:
-
- 1. Does this file make sense?
- 2. Who stands to gain in this transaction?
-
- Loan Application Red Flags:
-
- * Significant increase in commute distance
- * New housing not large enough to accommodate all occupants
- * Buyer is down-grading from larger to smaller home (except empty nesters)
- * Buyer currently resides in property (purchasing from landlord)
- * Buyer intends to rent/sell current residence with no documentation
- * Down payment other than cash
- * Stocks, bonds (liquid assets) not publicly traded (may be closely held corporation.
- * Face (not cash surrender) value of life insurance policy shown as liquid asset
- * Personal property value exceeds one years salary or high income buyer has no personal property
- * New housing expense exceeds 50% of current housing expense
- * Inappropriate salary with respect to amount of loan
- * Invalid social security number
- * High income / no credit
- * High income, no other real estate owned and renter for substantial period of time
- * Stock broker who does not own stock
- * High income / finance company, furniture rental debt
- * Self-employed but no entertainment-type credit cards
- * Low income or young buyer with substantial cash in bank
- * High income / little or no cash in bank
- * Buyer has checking account but says source of funds is "cash on hand" due to not believing in banks
- * Handwritten application shows no debt but typed application does
- * Information inconsistent with other loan documents - credit reports vs. Verification of Employment vs. Verification of Deposit, etc.
- * Inconsistent buyer signature or handwriting throughout file
- * Same person appearing throughout file such as landlord, seller, buyer, employer the same
- * Excessive cash deposit
-
- Verification of Employment (VOE)
-
- * Current and prior employment overlap
- * Round dollar amounts
- * Date of hire is weekend or holiday (per perpetual calendar)
- * Income is primarily commissions (self employed)
- * Employer uses mail drop or Post Office Box address
- * Borrower changed profession from previous to current employer
- * Illegible signature with no further identification
- * Business entity not in good standing or registered with applicable regulatory agencies
- * Co-borrower maiden name same as signature of employer (self employed)
- * VOE completed same day as ordered
- * VOE says company car and applications shows auto loan
- * Whiteouts, crosscuts, "squeezed in" numbers
- * If VOE not creased (folded), may have been hand-carried
- * Income out of line with type of employment
-
- Verification of Deposit (VOD)
-
- * Cash in bank not sufficient to close
- * New bank account (verify previous)
- * Round dollar amounts (especially in interest-bearing accounts)
- * Gift letter which is not backed up by VOEs
- * Closing check drawn on different bank
- * Buyer has no accounts (doesn't believe in banks) but VOD in file
- * IRA shown as liquid asset
- * Loan secured by checking or savings account
- * Illegible signature with no further identification
- * Significant changes in balance orm prior two months to date of verification
- * Source of funds consists of (unverified) note, equity exchange, sale of residence
- * Excessive balance in checking account
- * Date of verification by bank is weekend or holiday (per perpetual calendar)
- * VOD completed same day as ordered
- * Whiteouts, crossouts, "squeezed in" numbers
- * If VOD not creased (folded), may have been hand carried
- * Post Office Box for depository if not typical for area or company
- * Checking accounts with average two-month balance exactly equal to present balance
-
- Appraisal
-
- * Ordered by any party to transaction (Buyer, Seller, Realtor)
- * Comps not verified as recorded (data source MLS, Sales Office, Real Estate Agent, etc.)
- * Tenant shown to be occupant on owner-occupant application
- * Income approach not used on tenant-occupied SFDs
- * Excessive adjustments in urban or suburban area where marketing time is under six months
- * Distance of comps
- * Comparison of square footage to value
- * Photos do not match description of property
- * High land value in urban areas
- * Undesignated appraiser
- * Appreciation in stable or declining area
- * "For Sale" or "For Rent" signs in yard or windows
- * Appraiser located outside of subject property county
-
- Title Search
-
- * Tax or similar liens against buyer
- * Delinquent property tax
-
- Tax Returns
-
- * Real estate taxes and/or interest paid but no rental or owner-occupied property on application (or vice-versa)
- * Amount of source of income disagrees with other information in loan file
- * No dividends on stock
- * Substantial cash in bank with no related interest income
- * Gross income does not agree with total income on W-2s or 1099s
- * Buyer shows interest expense but no related liability (business loans with personal liability)
- * Buyer takes depreciation deduction for Real Estate not disclosed (or vice-versa)
- * Net income from rents plus depreciation does not equal cash flow as submitted by buyer
- * Additional properties listed but not on loan application
- * Buyer shows partnership income (may be liable as general partner for partnership's debts)
- * Invalid employer ID# on W-2
- * FICA and local taxes (where applicable) exceed ceilings
- * Copy submitted is not "employee's copy"
- * Different tax preparer each year
- * Low income employee used tax preparer for 1040 short form
- * If previous year shows preparer, is fee paid deducted on following year's return?
- * Paid preparer hand-writes tax return
- * No interest expense; however, credit outstanding
- * Dependents on loan application but not on tax return or vice-versa
- * No salaries paid on non-service self-employed P&L
- * No costs of goods sold on retail or similar operations
- * Address and occupation differs from application
- * W-2 from large corporation hand-written
- * Social security numbers on return different from application or credit report
-
- Credit Report
-
- * No credit (possible use of alias)
- * Variance in employment or residence data
- * Several recent inquiries from credit card companies or other mortgage lenders
- * Invalid social security number
- * Length of time on file inconsistent with buyer's age
- * Co-buyer's maiden name show data different from application
- * Age over 25 with no credit history
- * Personal data not consistent with handwritten application
- * If late pays due to unemployment because of illness, layoff, is VOE income less during this period
-
- Closing Instruction
-
- * Cash paid outside escrow
- * Down payments paid into escrow upon opening
- * Reference to another (double) escrow
- * Related parties
- * Unusual credits with no economic substance
- * Right of assignment
- * Power of attorney
- * Seller is corporate (except for developers, RELO Companies or REO)
-
- Sales Contract
-
- * Seller is Realtor, relative, employer
- * No Realtor
- * Lease-option
- * Price substantially below market value
- * Second mortgage
- * Deposit checks have inconsistent dates (check #1324 dates July 20 / check #1323 dated August 24)
- * Name and address on deposit check different from buyer
- * Deposit check not cashed
-
- Payroll Checkstubs
-
- * Debts reflected as deduction from pay (credit union loans, etc.) not disclosed on loan application
-
- Miscellaneous
-
- * Require all borrowers to sign release of tax information form
- * Do not accept incomplete handwritten applications
- * Call borrower at work and at home at least once during loan processing
- * Call employer on closing date to verify still employed
- * Run in-file report on closing date to check for additional incurred debt
-
-
- If you want to do everything that you can to create the best mortgage
- possible, you may want to download a FREE SOFTWARE PROGRAM from this
- forum. Go to the Software Library section and look for the listing
- "Loan Officer In A Computer", listing date 12/4/94. This contains the
- program, "QualifyR" --- Home Buyer's Qualification Program For
- Residential Financing. (For Windows, ASP author)
-
- Unlike other mortgage computation programs, QualifyR incorporates Fannie
- Mae Guidelines in its computational structure. Perhaps most
- importantly, the program computes and itemizes the Closing Costs of
- financing, Monthly Income Required, Private Mortgage Insurance, and all
- other variables in an actual mortgage, then displays a Financing
- Estimate screen in the same format as the Good Faith Estimate that the
- buyer will receive from the lender.
-