CFPB investigates Zillow’s Co-Marketing Program: What Agents Should Know

 

The CFPB’s recent action against Zillow speaks volumes about the mortgage industry’s regulatory atmosphere when it comes to advertising compliance. With costly fines and other serious penalties for marketing rule breakers, loan officers and their business partners can’t afford to ignore the signs of the times.

To help you navigate this arena with confidence, we have gathered the following information detailing the most common compliance blunders they encounter, with 3 ideas on how you can avoid potentially disastrous mistakes.

Always split payment, and show proof

All co-marketing material/expenses must be split based on pro-rata share, and be documented. This means if I pay for half of a co-marketing flier with you, the flier needs to show both of us, with an equal share of the marketing space. You also need to retain copies of checks, co-op forms, etc. when marketing with another person.

Get use to the verbiage

Unfortunately, mortgage compliance can take the fun and elegance out of marketing. We cannot boast about having the best rates or guarantee to close a loan within a set number of days. If your referral partner is engaged in these kinds of promises, it could be best to have a conversation with them, or if need be, steer clear of them altogether since this kind of rhetoric is inviting trouble.

Get use to the disclaimers

Our disclaimers are required by law. We know how ugly some of the long regulatory verbiages can be, or how picky marketing materials have to be to avoid triggering massive disclosures. However, as frustrating as these can be, there is no room for flexibility. The disclosures have to be there to protect everyone involved. If we don’t include these on our advertisements, it will be a serious reason for concern.

If you have questions about our industry, please let us know. We’d be happy to assist you in any way we can! The Polder Group at Summit Funding

Your HomeReady

 

Segments of the potential mortgage market are completely ignored by some lenders. Not only is this a poor business choice, but ignoring certain populations can be seen as a discriminatory practice by regulators. At PRM, we want to serve all communities and bring the dream of home ownership within reach. Through Fannie Mae’s HomeReady program, we can help you to grow your business in underserved communities for credit-worthy clients with low to moderate income. With flexible income guidelines not seen in other conventional programs, HomeReady helps PRM to assist you in bridging the gap for clients who otherwise would have limited financial options. Segments of the potential mortgage market are completely ignored by some lenders. Not only is this a poor business choice, but ignoring certain populations can be seen as a discriminatory practice by regulators. At The Polder Group, we want to serve all communities and bring the dream of home ownership within reach. Through Fannie Mae’s HomeReady program, we can help you to grow your business in underserved communities for credit-worthy clients with low to moderate income. With flexible income guidelines not seen in other conventional programs, HomeReady helps The Polder Group to assist you in bridging the gap for clients who otherwise would have limited financial options.

 

HomeReady Flexible Income Guidelines

 

  • Rental income acceptable
  • Boarder income acceptable
  • Non-Occupant Co-Borrowers acceptable
  • Expanded eligibility for lower income families by potentially using income derived from occupants other than the borrower as a compensating factor
  • Flexible DTI requirements
  • HomeReady increased home affordability in other ways, with low down payment options, which can be less than the required amounts for FHA loans. Additionally, your client also doesn’t have to be a first-time homebuyer, and properties can be more than 1 unit.

 

In order to qualify for the HomeReady program, your client must meet income requirements for the area the subject property is located in.  For low-income census tracts, there are now income limitations. Income limitations by area can be viewed

Here.

https://www.fanniemae.com/singlefamily/homeready-income-eligibility-maps

 

 

If you have a client you think might benefit from the flexibility of the HomeReady Program, contact The Polder Group Today.