Lykken on Lending

[David] And so let’s get over to Alice Alvey, Vice President, Partner Education and Training at Union Home Mortgage. Here with the Legislative Update, Alice, thank you so much for being here. And also for your partnership to this podcast for 15 years. Thank you so much.

[Alice] You’re welcome. Oh, excuse me. You’re welcome, Dave. Happy to be here. Just want to remind everybody we’ve got Juneteenth coming up this week. So hopefully you have the opportunity to take some time and celebrate the meaning behind Juneteenth with the ending of slavery. So this formal ending of slavery, finally, many years, several, I think it’s three years after the actual date. Just want to make sure everyone recognizes that day. It’s an important day and then I want a quick follow up to what Adam was reporting on the VA circular 26-2414, where we now have the assurance from VA that they’re going to move forward so that when August 10th does roll around, which is about when this settlement will go into play, We should be okay with our VA loans. One quick side point to add though, is you’re going to need a copy of that broker agreement in the file in those cases. Typically, we don’t get that in our loan files, so keep in mind that’s probably going to get triggered or is triggered on your VA loan. Just when we need more paper. One other update that I’m going to give you is on the CFPB. They have posted this notice of proposed rulemaking to the Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information. They have been working on this a long time. We’ve talked about different bits and pieces of this that have come out over the last several years. So they now finally have this proposed rule. You have the ability to comment up until August 12^th and then they will close that down and probably just move forward with implementing it anyway regardless of what the comments might be. Because it is considered pretty consumer friendly. I did not mean that as a slam against CFPB. I know they will do their due diligence, but for folks who don’t know where we’re at today, When you have a medical collection account as of March 31st of 2023, those are no longer reported on your credit report if it’s under $500. And then for larger collections, medical providers don’t typically report to a collection agency. And it doesn’t happen until the provider actually passes it off to some type of collection agency, which could be whatever that provider’s window is 30, 60, 120 days. It’s delinquent, then they’ll send it to a collection agency. And then from there, the credit bureau, so Experian, Equifax, TransUnion, they won’t report it for one year. So, you really have that kind of a lag before something, first of all, hits your credit report. So that’s where we’re today. And what the CFPB is proposing is that medical collections are just not reportable ever under any circumstance. They don’t go on the credit report. I think a lot of people find that very appealing. MBA pointed out that as lenders, we may experience feel like we have a bit of a blind spot on that. I have not had a chance to read the research that CFPB is citing. They’re citing two different reports, but they sponsored one of them. So I’m always a little and I like unbiased studies, and I haven’t had a chance to dissect them at all to see if those studies really do support that leaving the medical collections off won’t leave us with a blind spot in someone’s ability to repay. I think it’s going to happen. And as lenders, we’ll just have to try and find a way to, I don’t know how we can watch that because it won’t be on the report. So, once it’s gone. And then we’ll have to watch things from there. So, you have till August 12th to comment if you have strong opinions on that.

[David] It is, and we should be commenting for those that hear these kinds of things. We should be commenting. And I thank you for the reminders that you give us, Alice. How did they comment again? Refresh everyone’s memory on how do they go in and comment? I know we got mortgage action Alliance. You could do that through the MBA, but also CFPB has their websites and they can do.

[Alice] When you go to the CFPB website you can see under rules, they’ll have this one listed under their proposed rules and right there, you can see all the different ways that you can respond. You can also use your favorite search engine and just type in this particular proposal. Just if you say CFPB consumer reporting agencies concerning medical information, it’ll come up, take you straight to the CFPB website, and it can show you the multiple ways. You can just simply post directly from their website or if you like old school and you want to mail a letter, you know what? You can still do that too.

[David] Hard to believe anyone still does that. Yeah. Who’s got stamps? I don’t know. I’ve got, I bought some for some of these forever stamps. Then I looked back at what I paid for them. They’re half of the cost of what they are now. I bought it so long. I just don’t do as much of the way, man. Mr. Kittles stamp. He’s got his stamps folks, there he goes. Yeah. We’re all on a zoom call. Look at each other, even though you’re listening to this on audio basis. Good job.

[David Kittle] I still send out handwritten note cards.

[David] that is so good. I ain’t got, I got a handwritten. Comment from Dan Archibald of Total Expert the other day because I helped him close on a deal and I got a handwritten note and I remember when I get those, I go, dang, Brittany Hodak does that also and they’re so impactful when I actually get something in writing like that. We’ve got a few listeners that will send in comments. Almost 99. 99% of everything we receive is so positive about the podcast. And so, I really appreciate that. So however, you want to do that, it’s good. Thank you, Alice, for the reminder. We can still write if you’re so inclined.

[Alice] And don’t forget, if you’re going to send a letter to somebody who’s in, Gen Z, you better print because that’s the generation that didn’t learn cursive. So I have that with my nieces and nephews, my younger one.

[David] Yeah. It’s really interesting. I’m a cursive writer and I do my journaling. I do it all in cursive. And it’s something about. Connecting something about a ball, a pen to paper, actually a pen to paper and actually journaling and doing so in a cursive manner connects your brain to your subconscious and your heart a little better. And some things pour out. It’s really interesting studies coming out on that. So, they’re trying to get cursive writing back introduced to that. So,

[Alice] I’m a fan of that. Me too. I’ll vote for that. I’ll vote for that.

[David] Also, I want to say something. You mentioned CFPB and something that I think I’m on a phone call every Friday with Taylor Stork and Greg Sher and we talk about some of the issues and Taylor Stork knows Chopra is in his office, rarely, regularly, not like he knows him personally, like they’re best friends or anything, but Chopra reminded him last time he was in there. Taylor is the guy that works with CHLA and is a part of that and I think he’s the President of it. And he was in there and Chopra says, you know what? Just go take a look at the number of enforcement actions under my leadership as opposed to my predecessor’s leadership. It’s the lowest number of enforcement actions and we’re hearing rumors that they’re going to step it up. Now that they have the Supreme court ruling behind them on their funding. We shall see, but I hope that stays the case. Chopra, keep it low, go after what’s significant, but keep it low. Thank you, Alice Alvey so much for your updates. You could go listen to the Lykken on Lending website. If you say, boy, I like that. It’s so much good stuff. Go to the Lykken on Lending website. You can binge on Alice by listening to all of her comments.

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Alice Alvey, Master CMB
Vice President Partner Education and Training at Union Home Mortgage
8241 Dow Circle
Strongsville, OH 44136
D: 440.420.4294
C: 248.941.1939

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!