| ID | Status | Date | Public/Private | Industry | AHACPA Contact |
|---|---|---|---|---|---|
| #7843 | Closed | public | FHA Lender |
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In selecting a sample for loan origination and loan settlement testing. Should the population of FHA loans for the year include FHA loans the client originated as a TPO (aka brokered loans) or can these brokered loans be excluded as they are ultimately the responsibility of another lender? |
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From Mike Olsen: That may depend on who’s name the loan was closed in. Since your client is an approved FHA Lender, I would think you would include all of the loans they originated, including those that were originated as a TPO, in the sample. Because they are an FHA approved lender, and are functioning as a TPO for another mortgagee, they are allowed to close the loans in their name. If the “Brokered” loans were originated prior to their being FHA approved, then I would exclude them from the sample. However, if they were originate while they were approved, then I would think they should be included in your sample. They have a responsibility to comply with origination and settlement on all FHA loans that are originated while they are an approved mortgagee. |