New Loan Closing Advisor Feedback Messages for State-specific Rules
On October 1, we’re adding new Warning edits and Warning feedback messages in Loan Closing Advisor® related to state-specific anti-predatory lending laws and regulations. These messages will alert you when loans you’re originating may exceed the States’ threshold that triggers the application of the State high-cost loan requirements.
With this information, you can identify and solve potential issues before loan closing and prior to delivery in Loan Selling Advisor®. This will help you ensure the loans you’re selling to Freddie Mac meet the Points and Fees and APR high cost thresholds subject to the state anti-predatory lending laws and regulations as noted in Single-Family Seller/Servicer Guide (Guide) Section 4202.
Here's what you need to know about the application of the new, state-specific rules in Loan Closing Advisor:
- Apply to owner-occupied (primary residence) loans.
- Applicable for the states listed in Guide Section 4202.
- Use the Regulation Z Total Loan Amount and Regulation Z Total Points and Fees Amount provided in Loan Closing Advisor to derive the points and fees percentage that is then compared to the state-specific points and fees threshold.
- Use the APR Percent and Average Prime Offer Rate Percent provided in the Loan Closing Advisor to determine compliance for the APR High-Priced Covered Transaction (HPCT) thresholds.
If you receive a Warning message that a state-specific Points and Fees and/or APR to APOR threshold is potentially exceeded, verify that the data provided is accurate. If the data is not accurate, correct the data in the Uniform Closing Dataset (UCD) XML file and resubmit to Loan Closing Advisor prior to delivery in Loan Selling Advisor.
Please review the October 1, 2023 Release Notes for a full list of the new, state-specific feedback messages, as well as updates to and removal of existing messages.