[David] Let’s get over to Alice Alvey with your update on the legislative happenings. What did you think about the FEMA changes, flood insurance, Alice? Any thoughts on that, starting with that one?
[Alice] Yes, absolutely. So there are actually two things to cover today. One is to expand a little bit on MBA’s report on that FEMA RFI. So those comments are due December 10th, and this is a case where I would recommend everyone to send their comments to the MBA Because this is a very comprehensive RFI covering all their operational components. And a lot of what FEMA does directly has more of an indirect impact for us, right? So if they change how they’re mapping, if they change how they’re communicating their data or changes, then we have to make sure we’re staying in the loop with that. If they change notification requirements, we have to make sure we understand how all that’s going to work. And having a collective response in this case to me sounds much more effective since FEMA’s asking. So there’s a 15-page RFI. The other thing that’s unique here is you have to do it in a PDF and send it to one of these email addresses that’s- Right … in the RFI request. It’s a little different than, some of the ways that are so easy to send it in online. But I do think, that the, future of the flood risk data and the mapping, that’s a big issue to us. I think consumer communication and appeals, it doesn’t seem like they’re looking at changing how that process would go, right? For us, that comes into play where a consumer’s in the flood zone, and we’re trying to figure out if we can get them out of it so that we don’t have the insurance costs. So I think the thing to watch is see if the things that they’re gonna be putting in place are going to be increasing the costs for the consumer. I think, where one of the biggest concerns are. That’s my initial touch on that one. so affordability could be tougher if they tighten up how the maps are done and if more people end up in a flood zone, is basically- Yeah I think what we’re concerned about.
[David] Yeah. I’m concerned about that, especially when you talk about the Florida market, where you looked at homeowners insurance has already gone up so much. You talk about changes in the flood insurance and the impacts it’s gonna have on markets like Florida, along the coast, where we have had to deal, where FEMA has, have had so many impacts. But, who would’ve thought we’d have seen that in North Carolina, that- not long ago. So FEMA, big issue. Flood insurance- Yeah … big issue. And anything you can do, listeners, to have your word h- heard. They say I don’t know what to say. What do I do?” You know what? Find out what your company’s doing. If you’re out there, I think it’s important to have you say your voice heard. Find out what your company’s doing, find out what the MBA is doing. MBA is doing a good job in leading us on this issue. Take a look at their position. Get yourself behind it. It does-
[Alice] Yeah, and I think consumer specific stories are always helpful. Yes. Don’t ever feel like, oh, I had this one thing happen one time, is that really that relevant? very often those types of things do happen on a wider scale. If you’ve had something happen related to flood zone determinations or working with FEMA- That’s such a good point … so I would take a look at it. And, here’s a little hint. AI can help you get through that real quick. Yes. That’s so true. So it’s not like the old days where we had to sit around. Now AI makes mistakes, but if you have a particular aspect of how you deal with FEMA or flood insurance or- Yeah … notifications or consumer communication that’s so might be some shortcuts in there for you. The other one is the Telephone Consumer Protection Act. So this was very unusual. Interesting. FCC came out and there was a provision that was gonna be changing some of the, what I’ll just, they say, they use the word revocation, but it’s really your opt-out methods. I don’t want- the texts, I don’t want to be contacted by telemarketers. So as a consumer you go, “Yeah, tighten that up as much as possible so I don’t get bothered.” But from a mortgage lending standpoint, there’s a lot that your marketing department, your servicing departments, and origination departments have to think about. Please take a look at this. This new order is in effect, actually, as of November. So they moved up the implementation date from January- … 31st to now it’s November 25th. these should be some easy modifications to make, but some of the things that are helpful is it allows a business to treat an opt-out request for informational calls or texts to be to a category rather than for a blanket communication. That’s good. It permits callers to designate a specific automated channel. So you can say, ” I must receive a text that says stop in order to get you off my list,” versus, ” You cannot just tell my loan officer to take you off our list.” So- … that’s a good aspect. So it’s those kind of little nuanced things that go into effect, so please check that out, ’cause that implementation date was moved up. But also check that they, same day, published a new RFI on all of this, and how should all of this work. So again check out both. You have some rules, a few of them that you have to implement or can implement right away. But then also take a look at the RFI that the FCC published on TCPA. How’s that for alphabet soup on- … how to get your telemarketing right. I’ll leave it at that, Dave. If folks have any questions they can reach out to us, but there’s quite a bit that you would want to comment on related to origination and servicing as far as fraud alerts and other billing and account management topics.
[David] Yeah. Very good, Alice. Very good. There’s so much going on. I’m gonna be doing an interview of Amanda of Lanny Bay, and she is heading up a new committee. She’s the new chair of a committee at the MBA. And there’s so many regulatory sides of this puzzle that are really impacting it. So I encourage you to get involved. The most important thing, you don’t think you make a difference, you can get involved. Start with MAA, Mortgage Action Alliance, and then just study up, stay up. You say I’m just a loan officer. Don- my voice doesn’t matter.” Yes, it does. Yeah. I think the most important thing Alice said was tell stories. There’s a lot of people that have opinions But the thing that’s most relevant that really moves the needle is a story. Let me tell you a story of a borrower I have. You may have your own borrower, but it can make such a difference in moving the needle. Don’t underestimate-
[Alice] And if you don’t have a comment, you can’t complain, right? Yes. To the statement earlier. If you don’t vote, you can’t complain. If you don’t vote, you don’t complain. Exactly right. Spot on, Alice. Thank you so much. Good job. Excellent.
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!