Is non-delegated lending the next logical step for wholesale mortgage brokers?

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“I’m working on doing more hybrid closings, how to expedite the wires, how to expedite the post-closing piece,” Miller said. “By the way, we haven’t talked about post-closing on a non-del loan, which is slightly different than when you do a brokered loan. I’m working on expediting that so that we get paid sooner. So it’s always a little bit of a moving ship.”

Keeping compliance in mind

Of course, for brokers considering the move into the non-del space, understanding compliance needs up front is critically important. Harris reminded everyone that there is much more reporting required when moving to non-delegated.

“We all know compliance is complex, and the switch from broker to non-del, from an operational standpoint, there is a lot more that you guys need to know about,” Harris said. “Most of the time with most of the lenders that you guys do business with will be responsible for initial disclosures, closing disclosures, pre-disclosures, even the content, the fees, etc., on those disclosures.

“Your mortgage call reports, MCRs, they get a lot more intense from a reporting standpoint. You’re reporting more information, more data points. Your financials will now be reported quarterly instead of annually.”

Another factor brokers will need to consider is that quality control reviews will now be required post-close.



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