[David] I wanna get it over to you, Alice. One of the things that there’s not a lot going on legislatively to talk about.
[Alice] I did have the one reminder for everyone about the consumer Financial Protection Bureau, having the eCOA changes, request for information that you can Yes. Respond to through December 15th. And just wanted to be, remind folks to get out there and take a look at that. This is a really big change. It would be a good change, in my opinion, to get them off of where, and we’ve all, many of us have lived this in audits, either directly or like myself, directly and through different clients where. You have a violation of the Equal Credit Opportunity Act by someone coming in and reverse engineering your hum to data and you didn’t have a policy. And I’ll use maybe since we love talking about rates, I’ll use rate exceptions as an example. If you say I make except rate exceptions in order to make sure loans close, that happens periodically. And that therefore at the end of a year in looking at that analysis may show some kind of disparate impact in a particular area or for particular protected class. Not through any policy that you had, but just through, what inadvertent data. And that can happen if it is just one or two loans, even though maybe you did thousands. So it would be great to have that aspect of kind of reverse engineering data to come up with findings. When you didn’t have a policy as a lender, it wasn’t any kind of overt policy to treat people differently in how you extended or managed rate exceptions, just in as one possible example. So I think it’s definitely worth, as an industry to get in there, comment. There’s lots more to comment about that, but that is, yes, getting this aspect removed so that it is just what are your policies and where are you, what you know? Are you implementing your policies correctly and your policies are fair and treating people equal? That should be the focus. So hope everyone gets out there and comments, but, and thank you all in honor of Thanksgiving. Thank you everybody here. It’s great doing the program with you. I learn so much every week. I have pages and pages of notes and it’s a pleasure working with all of you.
[David] It’s a joy to have you here, Alice, and the contribution you’ve made over the decades and decades we’ve been doing this together. It’s just astounding. Hard to believe it’s been that long. But it has, and we do enjoy you. 18 years, I think. Yeah, 18 years. It’s hard to imagine. 18 years of doing the same thing every Monday. And then oftentimes we were doing that for a couple times a week. But anyway, it was great. And so thank you for your contribution, so grateful.
Alice Alvey, Master CMB
She handles development of their World Class Training program designed to support UHM partners and organizational effectiveness.
Prior to UHM, Alice served as Senior Vice President at Indecomm leading the Indecomm-Mortgage U division, Internal QA and Compliance and SaaS technologies. Indecomm acquired Mortgage U in 2013, where Alice was President/Co-founder, providing training and consulting since 1996. Prior to MU she served as SVP of Operations at a national bank overseeing operations for wholesale, retail and correspondent from underwriting through servicing, and compliance.
She has been in the trenches of mortgage lending operations from application through servicing for over 30 years. Her authoring work in training content, policies and procedures and the FHA/VA Practical guides illustrates her ability to bridge regulatory requirements with day-to-day operations.
Alice has been a weekly contributor to the Lykken on Lending show since its beginning in April 2009 and has made her weekly contributions to 450+ episodes!