Compliance Newsletter - July 2021
96
DocMagic
Did You Know: You can cut out the middleman and draw your own docs?
Some lenders pay an intermediary, such as a law firm, processing center or fulfillment company, to generate their mortgage documents and conduct print fulfillment services.
However, lenders can cut out the middleman and draw their own docs — at the exact same quality and at a fraction of the price — by using DocMagic’s document generation solution for initial disclosures and closing documents.
“I think some lenders are hesitant to take on that doc gen burden,” said Aimee Eyre, a sales executive at DocMagic. “But drawing their own docs is easier than they think, and it would save them a lot of money.”
Another reason that lenders use a fulfillment company is because many lack an in-house compliance expert and the intermediary companies offer compliance checks as part of their service — but so does DocMagic’s doc gen solution, which includes an automated compliance system designed to catch any errors and issues before documents are processed. 
In fact, “a lot of fulfillment companies that use DocMagic advertise that they’ll handle the compliance piece for the lender, but they’re actually using DocMagic’s compliance system,” said account executive Shandi Smith.
Smith and Eyre often get calls from lenders who realize their fulfillment company is using DocMagic for document generation.
“They say, ‘I saw your logo in the bottom corner of the box and wanted to talk to you directly,’” Eyre said.
To reiterate, there are a host of advantages for lenders who draw their own docs, including:
- Money: What DocMagic’s document generation clients pay to draw a doc gen set is a fraction of what they have to pay to the intermediary companies to do it for them.
- Time: When lenders use DocMagic, it takes less than 10 seconds to generate a doc set. When lenders go through an intermediary, the process is out of their hands; they have to get in line and are at the mercy of whatever time frame the fulfillment company sets, which could be as much as two to three days. By using DocMagic’s document generation solution, lenders have the power to pull documents on their schedule, putting them firmly in control.
- Compliance: DocMagic’s document generation solution comes with built-in compliance checks, supplied by an expert team that’s constantly monitoring the regulatory landscape to ensure the document library is evergreen. As Smith noted, in many cases, lenders are already getting DocMagic’s compliance service if their fulfillment company is also using DocMagic.
- Ease: Some lenders worry that generating their own documents is a complicated process. That couldn’t be further from the truth. “As soon as you show lenders a demo, they realize that it’s not as hard as they thought it would be,” Eyre said. Smith added that after lenders are trained, they become extremely proficient at pulling their own docs.
DocMagic’s Sales Team can be reached at sales@docmagic.com.
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3 reasons why your post-closing department loves eClosings and eNotes
Lenders are finding there are a host of upsides to eClosings — and their post-closing departments are reaping some of the main benefits.
In a series of recent webinars, DocMagic clients reveal three key reasons that their post-closing departments prefer digital closings, and especially eNotes (electronic promissory notes):
1. No more time wasted hunting down missing signatures or initials.
This is actually a benefit with any eClosing, including basic eSign Hybrids that produce paper promissory notes.
“The post-closing department, previous to eClosings, had to scrub every document for accurate signatures. For some reason, borrowers just simply could not find the exact same name on every document,” said Chrissy Brown, COO at Atlantic Bay Mortgage Group, which has branches in nine states. “Did they miss a date? Do we have to go back and get something re-dated? Anytime you replace that human element with an electronic or technological advancement, you definitely increase your accuracy.”
Watch the webinar: True Stories: Hybrid, eNote and RON implementation
Beth Eller, the vice president of mortgage services at North Carolina-based Truliant Federal Credit Union, agrees. “The efficacy of it from an operational standpoint is tremendous. There is no missed signature. There is no missed initial. You can't move forward in an electronic closing without hitting every single one,” she said. “So that post-closing follow-up becomes really a non-event as far as the closing package itself goes.”
2. Speed and simplicity: It’s faster and easier to deliver eNotes where they need to go.
A common refrain among the clients was how quick and simple it is after the closing to transfer the eNote. With the click of a few buttons, the eNote is immediately registered with the MERS eRegistry and then sent via instantaneous eDelivery to the eVaults of various participants (whether the lender’s own or downstream to investors and servicers).
Once the eNote is signed, said Stephanie Zinsmeister, senior vice president of operations at AnnieMac Home Mortgage, “Boom, it's in MERS and it's ready to be sold instantaneously without having to transfer it [among] five or six different hands and risk losing that note.”
Jeff Reeves, co-founder and CTO of Canopy Mortgage, which operates in more than half the states, agrees: “It’s this simple: literally when that package is signed and you have an eNote, I go to DocMagic’s console, I hit the button to transfer Control and Location to the warehouse bank, and then they go into their system and they hit the button to send it to Fannie or to PennyMac or to whoever’s going to buy that loan from us.”
Watch the webinar: Managing a successful eClosing initiative
Truliant’s Eller noted that the immediate delivery of the eNote easily shaves six to eight days off the servicing and backend process. Loans can be sold immediately. “It is a better delivery method than paper, any way you cut it,” she said.
Additionally, there’s less of the traditional back-and-forth that happens with a paper note.
“You have one place that you go to grab that package,” Zinsmeister said. “You don't have to wait for paper to come in. You don't have to wait for a title company to email it to you. Post-close, I can just go in there and grab that closed loan package.”
This speed and ease of delivery is why Atlantic Bay’s Brown wasn’t too concerned when in August 2020, Fannie Mae and Freddie Mac suddenly instituted a new Adverse Market Refinance Fee that added 50 basis points to most mortgage refinances.
“Luckily, that [fee] got extended, but in that moment, it was amazing to have that eNote capability … we were able to deliver a lot longer into the process than some of our competitors that didn’t have that [eNote] process, because we’re able to sell instantaneously,” she said.
3. Paper notes can be lost, while eNotes are impossible to lose or destroy.
Let’s be honest: Sometimes FedEx or UPS mess up.
As the lenders noted, with just a few clicks, eNotes are instantly sent where they need to go. With paper notes, however, lenders have to rely on a shipping company such as FedEx or UPS to deliver the note to the correct custodian. But this leaves room for human error, and many, many lenders know what it’s like to have the delivery service lose a note.
In April, UPS lost one of Canopy Mortgage’s paper notes. Usually in such a scenario, the borrower is willing to re-sign the note. Not in this case.
“This person was a real estate attorney and made a huge stink about the fact that he didn’t want to sign another note because it’d be a duplicate, and somehow, we were going to shaft him because we have two notes. ‘What if we found the other one?’ and on and on,” Reeves said. The borrower forced Canopy to draw up an indemnity document with their attorneys.
Despite that, the borrower still refused to re-sign the note. “So here I have this $400,000 note that, really, I can’t do anything with, because UPS lost it,” Reeves said. “If that shouldn’t scare you into wanting to do eNotes, then I don’t know what will.”
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ICE Mortgage Technology deploying DocMagic’s eVault tech for Encompass LOS
ICE Mortgage Technology, a leading global provider of data, technology and market infrastructure, is deploying an eVault solution for secure storage of digital mortgages and notes, based upon technology acquired from DocMagic.
The eVault technology will be integrated into ICE’s mortgage closing platform, Encompass eClose, a leading-edge solution that helps to transform the way loans are electronically closed in the United States. Encompass eClose enables lenders to electronically facilitate every aspect of the eClosing workflow, from ordering documents to delivering loans to investors — and all steps in between — without ever having to leave Encompass, the industry’s most recognized loan origination system (LOS).
“ICE Mortgage Technology and DocMagic have been helping lenders implement digital mortgage processes for years,” said Dominic Iannitti, president and CEO of DocMagic. “The migration towards digital mortgages is progressing quickly, and we’re happy to have provided ICE with capabilities to enable fully-paperless lending workflows along with better supply chain connectivity.”
Both ICE and DocMagic are committed to delivering technology to increase eClosing adoption in the mortgage industry.
“By creating an end-to-end solution and further automating the mortgage closing process, we’re helping the industry transition to paperless closings and enabling more efficient processes for our customers,” said Joe Tyrrell, President, ICE Mortgage Technology. “We acquired technology from DocMagic, who has deep experience in the mortgage space, and when this technology is integrated with our other services, Encompass eClose will enable customers to eliminate time and cost in the closing process and create better experiences for borrowers.”
ICE Mortgage Technology combines technology, data and expertise to automate the entire mortgage process from consumer engagement through loan registration. Today, more than 3,000 mortgage lenders, 45,000 agents, as well as technology partners and mortgage investors can use the powerful capabilities of ICE Mortgage Technologies solutions to drive efficiencies and profitability for their businesses.
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AmeriSave leverages DocMagic’s Total eClose, doc gen solutions to maximize productivity
AmeriSave, one of the country’s largest mortgage lenders — best known for pioneering the first truly digital mortgage experience for borrowers — has been utilizing DocMagic’s Total eClose and document generation solutions to drive digital mortgage efficiency.
"DocMagic has been a wonderful partner to work with throughout the pandemic and refi boom, proving to be a key technology partner that has helped rapidly scale AmeriSave," said Magesh Sarma, AmeriSave’s CIO. "We look forward to continuing our partnership with DocMagic to establish even more efficiencies for our customers and internal teams."
AmeriSave, which offers simple self-service options so that borrowers can directly engage in the loan process, has grown exponentially over the past several years, in part by leveraging DocMagic’s technology to establish system-wide interoperability, newfound business process efficiencies, compliance adherence, and more. DocMagic’s document preparation solution, eSigning and eClosing technology, which integrate tightly with AmeriSave’s proprietary loan origination system (LOS), has helped AmeriSave operate smoothly throughout a volume-intensive environment.
Many of DocMagic’s functions automatically occur at the appropriate time within the workflow of AmeriSave’s LOS — without any human intervention whatsoever. This maximizes employee productivity throughout the lending process, including with many of AmeriSave’s vendor partners.
“AmeriSave understands the importance of always ensuring that borrowers have as many options and tools as possible available at their fingertips to walk away with a good experience that ultimately creates repeat business,” said Dominic Iannitti, DocMagic’s president and CEO. “Everything we do at DocMagic places ease of use, simplification and elegant design as a top innovation priority, which is reflected by AmeriSave’s ongoing achievements. We are elated that AmeriSave is having such immense success with our technology.”
Moving forward, AmeriSave plans to implement DocMagic’s remote online notarization (RON) capability, eNotes and eVault technology to establish further lending efficiencies.
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GSE guidance for revised General QM definition
Fannie Mae and Freddie Mac (FNMA or FHLMC, respectively, or the “GSEs” collectively) recently provided additional guidance on their changes in response to the revised General QM definition, as well as their Preferred Stock Purchase Agreement (“PSPA”) with the Federal Housing Finance Agency (“FHFA”).
As we discussed in our prior article last month, “GSEs announce plans to limit purchases to loans meeting revised General QM rule,” the GSEs have entered into a Preferred Stock Purchase Agreement with the FHFA which requires the GSEs to only accept for purchase those loans meeting the new, revised General QM definition as of its original mandatory compliance date on July 1, 2021. The CFPB has since officially postponed the mandatory compliance date of the new rule to October 1, 2022, as discussed here.
The new guidance released by the GSEs last week reiterates their previously announced position, that due to the terms of the PSPA with the FHFA, only loans meeting the new definition of General QM will be accepted for purchase, as of loans with an application date of July 1, 2021 or after, or with a settlement date after Aug. 31, 2021, no matter the loan’s application date. Effectively, this means there will be no “GSE Patch” or Temporary Agency carve out to the General QM rule as of these dates, and all loans with an application date of July 1 or later will be expected to comply with the new General QM definition.
Note, the GSE Patch to the prior General QM definition allowed loans eligible for sale to the GSEs to meet the General QM definition up until the sunset date (prior date was Jan. 10, 2021, then modified to match the new mandatory compliance date of the new General QM rule), or when the GSEs left conservatorship, whichever was later. However, since as of applications dated July 1, the GSEs will only purchase loans meeting the new General QM definition, then effectively, those loans are the only ones eligible for sale to the GSEs thus the only loans meeting the GSE patch rules as well. As a result, effectively, because of the GSEs' actions, there will no longer be any GSE patch as of July 1 (or Sept. 1 for loans with application dated before July 1 but not yet sold to the GSEs).
One exception to the new GSE requirements is for construction-to-permanent loans which may be delivered under the prior QM definition until Feb. 28, 2022 (for loans with an application date prior to July 1, 2021).
As a result, DocMagic is proceeding with our original plans for phasing out the QM rules that allow for the GSE Patch/Temporary Agency QM. Thus, for loans with an application date of July 1 or later, DocMagic audits will run only the revised General QM definition, without a DTI component. As of Sept. 1, DocMagic Online will no longer allow selection of Temporary Agency rules for loans with an application date of July 1, and any transaction submitting a QM Type: TemporaryAgency, will automatically have the new General QM rules applied instead. Users will still be able to run the Temporary Agency rules on loans with an application date prior to July 1.
Fannie Mae Lender Letter 2021-11
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Did You Know: You can get all your eClosing needs met by one vendor?
Some lenders think the only path to an eClosing is by employing a wide variety of vendors; for example, one vendor for document generation, another for compliance, another for electronic signatures, and so on.
But that’s a misconception. Not only is it possible to have a single-source vendor for all eClosing needs — it’s optimal.
“The lenders I speak to are really interested in using a doc provider that's foundational, that can provide everything,” said Darlyn Buthsombat, an account executive at DocMagic. “They want to use a doc provider that can also do eSign, that can also run all of the necessary compliance checks and have everything that’s needed for an eClose solution.”
An end-to-end technology vendor like DocMagic can provide what lenders need for every step of the eClosing process — something not even all DocMagic customers may realize. Lenders who are using DocMagic for document generation and eSignature are also in position to use the Total eClose platform to conduct any hybrid closing they want, or even a fully paperless eClosing, complete with eNotes, eVault and eNotarization options.
“Sometimes I will run into a customer that was using another e-signature vendor because they didn’t know that we have eSign available for the disclosures,” Buthsombat said. “And then once they see our solution, they switch because it just makes more sense.”
Lenders who use multiple vendors can run into a variety of issues, including:
- Inefficiencies and errors: Having multiple vendors adds more steps to the process, which also becomes noticeably slower as every step requires a wait for each disparate system to complete its job. Additionally, if a problem should crop up, it may take longer to resolve because of the uncertainty over which vendor may have caused it, forcing lenders to deal with multiple customer service teams. While DocMagic has an open application programming interface (API) to easily integrate with alternate technology solutions, other tech vendors may not have an open API, potentially disrupting the process flow between multiple vendors and resulting in duplicated efforts for the lender. By using a single vendor, lenders get a seamless experience, with the entire doc gen or eClosing process taking place in one environment.
- Compliance: While most vendors run their own compliance, it might only apply to their specific specialty, which could complicate the process. “When the system is using different vendors and they run compliance, it doesn’t know which interpretation to believe,” Buthsombat said. “For example, one vendor may run the compliance audit but not the high-cost test, so that vendor might have a question on their audits or different information relating to the high-cost test. It can create some inconsistency there.”
- Vendor management: It is simply more of a hassle managing multiple vendors versus having one. Multiple vendors lead to multiple logins and passwords, multiple accounts and billing cycles to manage, and multiple onboarding processes and training sessions. There’s also continued education and communication for updates, which can seem repetitive when received from several different providers. Lenders also have to do their due diligence and ensure that every individual vendor is adhering to all compliance and security standards.
Lenders could avoid all these issues by using an effective single-source provider with years of experience and a record of success.
A few weeks ago, DocMagic signed a new client who had been using five separate vendors: one each for document generation, compliance, eNotarization, eVault and ad hoc signing.
However, the client will now get all those services provided by DocMagic.
“They switched to DocMagic because they were looking for a single-source provider,” Buthsombat said. “They wanted to eliminate the additional steps and inefficiency caused by using multiple vendors. Now their eClosing process is more seamless and efficient.”
DocMagic’s Sales Team can be reached at sales@docmagic.com.
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Compliance Newsletter - June 2021
96
DocMagic
Ask the eClosing Team: Why are eNotes better than paper? (and other burning questions)
Welcome to Ask the eClosing Team, an ongoing series where DocMagic’s eClosing pros tackle real questions that we’re hearing from lenders. Today’s responses are supplied by eClosing Team member Ron Carrillo, who is also DocMagic’s Business Development Manager.
Why are eNotes better than paper notes?
An eNote is the electronic counterpart to the traditional paper promissory note, so it contains the same information (e.g. home address, loan amount, interest rate, etc.), though eNotes are electronically signed instead of wet-ink signed. On the screen, eNotes look like regular paper notes except that they contain language stating that they require electronic signatures, as well as language referencing eNotes.
“If you peel back the layer of what you are viewing, it is actually MISMO-compliant XML data,” Carrillo said. “This gives eNotes several advantages over paper notes.”
Ask the eClosing Team: What do lenders need to get set up for eNotes?
Here are some factors that give eNotes the edge over paper:
- Unlike a paper note, it’s impossible to lose an eNote.
When Carrillo asks lenders if they’ve ever lost a paper note, he often gets this response: “Oh yeah. Oh my goodness, yes.”
Simply put, paper isn’t the safest or most secure option. When lenders want to sell a paper note, they have to send the original note via courier to an aggregator, the GSEs, or perhaps an end investor. “And they put hands on that package and pray, ‘Dear, God, don't let this one get lost,’” Carrillo said. “But it happens, and when it happens it's disastrous, because that note is the loan. It's the original, and now that you’ve lost the original, what do you do?”
“The security of an eNote is that you don't put an eNote into a package to be mailed off,” he continued. “It's an electronic document. It goes into the eVault and it can be transferred to the eVault of an aggregator or investor without sending it via courier.”
- The eNote process is simpler, saving time and labor.
After investors receive a paper note, someone has to manually run it through an optical character recognition (OCR) machine to scan it and copy the data. After that, someone also has to eyeball the data that's being copied off the note to confirm it's accurate. “That's a manual task and all of that takes time, right? And they can still make an error,” Carrillo said.
These manual processes, plus the fact that the paper note needs to be physically mailed, could increase investor acceptance time to as much as two weeks. With an eNote, which doesn’t need to be scanned because it is MISMO-compliant XML data, acceptance times are reduced to three to four days.
- Post-closing, paper notes can’t hold a candle to eNotes.
Don’t just take our word for it; you can hear from the lenders themselves why their post-closing departments love eNotes so much.
“There are lots and lots of reasons why an organization should really look at digitizing their mortgage process,” Carrillo said. “It will build efficiency, it will build a better borrower experience, and it will build greater security for their documents and their loans.”
Here are some other common questions about eNotes:
What exactly is an eNote?
Obviously, a paper note is made of paper. An eNote may look like a digital version of a paper note on screen, but it’s not just a scanned PDF version of a paper note.
eNotes are created in a specific file format: XML data. XML (Extensible Markup Language) is made up of text-based code and is one of the most common formats used to store and transport content online. XML stores data in a way that can be easily read by and shared between software applications.
What is a SMART Doc® eNote and why do I need one?
So an eNote is made up of XML data — but how do lenders know exactly what information that XML data should contain, or what format it should take?
Enter MISMO, or the Mortgage Industry Standards Maintenance Organization, a subsidiary of the Mortgage Bankers Association. As its name suggests, MISMO is the mortgage industry’s standards-developing body, and the SMART Doc is MISMO’s technical framework for electronic documents. “MISMO says, ‘This is the way your XML data should look and this is the format it should be in,’ and that's the standard that everyone in the industry has to work toward,” Carrillo said.
While MISMO’s standards are technically voluntary, the major investors — including GSEs Fannie Mae and Freddie Mac — will only purchase eNotes that adhere to the SMART Doc format. To conduct a full eClosing or to use DocMagic’s Total eClose solution, lenders need to be able to generate a SMART Doc eNote, Carrillo noted.
What’s a tamper-evident seal?
Once the eNote has been electronically signed, a tamper-evident seal is applied to certify its integrity.
What that means: It’s impossible for someone to secretly make changes to the eNote. Even if they attempt to make a small change, such as deleting a space and fixing a typo, it will leave evidence that a change happened. Once that seal has been applied, “No one can fiddle with the numbers and fudge something later on down the road. Whatever you see on that document electronically is what it is,” Carrillo said. “If someone were to break that tamper-evident seal, it would indicate that the documents are not fully represented the way they were when they were signed.”
But in the paper world, Carrillo noted, “You can take a note, put some white out on it, and make a change.”
Since there’s no original paper note, how do we know who owns the eNote?
With paper, it’s clear who owns the note: whoever physically possesses the tangible, original paper note (as opposed to a photocopy).
But since no physical form of an eNote exists, how is its owner determined? Especially since each time eNotes are transferred from one stakeholder to the next, a new digital copy is created.
The answer: While several copies of the same eNote may exist, only one is deemed the “authoritative copy” — and whoever has the authoritative copy is the current owner of the eNote.
After the borrower signs the eNote, it is placed in the lender’s eVault, which includes a notation that this version is the authoritative copy. In official parlance, the lender has “retention of the authoritative copy,” Carrillo said.
When the lender wants to transfer the eNote to an investor, they have to initiate a digital transfer of the control and location of the eNote. There are many investors currently using DocMagic's eVault to accept eNotes from DocMagic customers. After the investor accepts the digital transfer, the investor’s eVault will indicate that its eNote copy is now the authoritative copy. While the lender’s eVault may still contain a copy of the same eNote, it will state that it’s not the authoritative copy.
The MERS® eRegistry also notes whenever the control and location of the authoritative copy changes.
What’s the MERS eRegistry?
The MERS eRegistry is the system of record for eNotes; if lenders plan to sell their eNotes, then they need to be registered with MERS.
When the eNote is registered, MERS assigns it a hash — a digital “fingerprint” made up of a string of letters and numbers that uniquely identifies a computer file, or in this case, the eNote — to track an eMortgage throughout its life. The eRegistry identifies the controller (owner/holder) and location (custodian) of the authoritative copy and will also note whenever that changes.
The eClosing Team can be reached at eClosingTeam@docmagic.com.
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Atlantic Bay surpasses 10,000 eClosings using DocMagic's Total eClose
Atlantic Bay Mortgage Group has processed more than 10,000 eClosings — including thousands of eNotes — with the help of DocMagic’s Total eClose solution.
A long-time DocMagic client, Atlantic Bay processed its first hybrid eClosing in 2018 and executed its first eNote in January 2020; by year’s end, the lender had registered more than 7,000 eNotes. As of May 2021, Atlantic Bay has surpassed 10,000 eClosings, representing more than 20% of all loans originated as paperless closings.
“More than anything, our success has been predicated on being early adopters of RON (remote online notarization) and eNotes, helping settlement agents become comfortable with DocMagic’s software, working closely with our warehouse lenders and investors to accept eNotes, and having a ‘just do it’ attitude toward eClosings with eNotes,” said Christina Brown, Atlantic Bay’s Chief Operations Officer. “All of the legwork that we performed before and in the early days of the pandemic helped us gain a lot of experience and we were able to execute thousands of eClosings. It’s now become a competitive advantage for us.”
This recent success makes Atlantic Bay a leader in the lending space.
“Atlantic Bay exemplifies an incredibly efficient lender that has made all the right moves to fully embrace digital lending and completely remove paper from the closing process with our Total eClose platform,” said Dominic Iannitti, DocMagic’s president and CEO. “When you put the necessary pillars in place like Atlantic Bay has, it paves the way to more scalable operations with paper-free eClosings at the heart of the workflow. … We’re excited to showcase them as a client that’s perfected the eClosing process.”
Total eClose allows lenders to implement every type of hybrid eClosing — including eNote and eNotarization options — as well as a 100% full eClosing. It offers an end-to-end paperless workflow that seamlessly connects every component of the closing process.
Brown said eNotes have been a boon for her company.
“From origination through closing, warehouse lending and onto secondary marketing, we’ve seen a tremendous upside to producing eNotes that has benefited us as a company, our staff and our customers,” she said.
Atlantic Bay has already been conducting eClosings with RON, but plans to increase its volume of RON closings. The lender reports that it has experienced increased accuracy; quicker turn times; strict compliance adherence; better secondary marketing sell-side efficiencies; more warehouse line liquidity; and a straightforward, speedy and pleasant closing experience for borrowers.
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