Best Practices II
Matters of Origination
As Argent | Ameriquest firmly adheres to the principal that
clients should 1) within a timely manner, be made privy to
full and complete disclosures pertaining to the terms of their
loan agreement; (2) been given sufficient time to review the
materials and, in turn, render their decisions (3) be permitted
to consult with an outside advisor prior to enacting into
any form of mortgage agreement.
1. Offering Clients a Duplicate Copy of their Credit History
Starting October of 2003, Argent | Ameriquest implemented
a policy by which they provided clients with both an Early
Disclosure Packet, as well as, a complementary copy of their
credit file. Plus, clients are to receive an informational
brochure instructing them on how to interpret data contained
within their credit file.
2. Full and Complete Disclosures of Terms of the Loan Agreement
Argent | Ameriquest will not permit loan information to be
misconstrued by company representatives. Therefore, they aim
to thoroughly relay all the pertinent facts about a loan agreement
to clients so that there is no confusion. As a helpful tool,
the Early Disclosure Packet is executed in automated-fashion
to ward out any errors that may occur via the manual imputing
of data. Within three days of receiving a candidate’s
loan application, Early Disclosure Packets are forwarded on
to candidates for their review and evaluation.
Plus, Argent | Ameriquest willingly discloses information
that is not mandated by federal or state laws. Such information
may include: available mortgage product options and the effect
their loan choice will make upon their finances.
More specifically, these volunteer disclosures may include:
Choices Pertaining to Advance Payment Charges provides an
overview of the choices available to clients with respect
to making payments. Such options may include: whether one
opts to be billed a charge for making an advance payment in
lieu of a reduced interest rate. Note: Advance penalty fees
only apply only to early payments made within a loan’s
initial three year period.
Choices Pertaining to Interest Rates and Lower Fee Points-
provides an explanation of the interconnected relationship
that exists between interest rates and lower fee points and
offers clients a series of rate and point options to consider.
Reviewing and Comprehending the Terms of Your Loan –
provides an understanding of the risks involved in using one’s
home as collateral against which to borrow money; precautions
for borrowing funds; a client’s right to cancel a plan;
the benefits of shopping around for the best loan rates and
terms, as well as, consulting with an outside advisor prior
to making any decisions.
Break-down of Mortgage Fees & Interest Rates – provides
an assessment of the myriad of costs and fees which may be
added onto a mortgage loan. Such costs may include: interest
rates on an adjustable rate mortgage; regular payment fees,
escrow accounts; loan origination charges, as well as, processing
fees and any possible prepayment fines.
Final Loan Agreement – provides a basis for comparison
between the initial good faith estimate and the final terms
of agreement.
Seven Day Cancellation - provides clients with a suitable
period for reviewing the terms of the loan agreement and being
able to cancel the transaction at zero cost and a full refund
of any moneys previously paid.
Assessing the Client’s Ability to Make Good on Loan
Lending practices employed by Argent | Ameriquest do not rely
solely upon the value of the real estate property. Rather,
they utilize an automated underwriting procedure via which
they can standardize the evaluation process. Based upon an
individual’s earnings, credit rating, mortgage history,
debt accumulation, filings for bankruptcy and instances of
foreclosure, they then equitably are able to render a decision
to approve or deny a candidate’s loan application.
3. Determination of Fair and Reasonable Points and Fees
Argent | Ameriquest will not originate any form of lending
agreements which are considered to be of a "high cost"
nature as defined according to the Home Ownership and Equity
Protection Act of 1994 (HOEPA) or as is also known as predatory
lending restrictions. For the most part, Argent | Ameriquest’s
typical fees fall below 1 percent of the principal amount
without adding on any additional third-party charges. Reduced
fee points are restricted to no more than five percent of
the principal amount, or lower, as defined by the state in
question.
.4. Assigning Fees based upon Risk Assessed
Argent | Ameriquest mortgage associates are trained to understand
the nature of our pricing structure. We employ risk-based
protocols by which we maintain a consistent pricing system
which we then pass on to our clients. Mortgage associates
do not have the authority to elevate any of the benchmark
figures which originate from the risk-based system. Clients
are given various options such as they may select a reduced
interest rate in favor of paying more in discount points or
vice versa. Yet, the practice of employing standardized pricing
is what allows Argent | Ameriquest to offer clients fair and
equitable products regardless of their background or social
status.
5. Connecting with the Community and Educating Consumers on
the Mortgage Industry
Argent | Ameriquest is dedicated to implementing broad-based
education initiatives whereby they are able to provide consumers
with knowledge and insight about mortgage practices. As an
outgrowth of this commitment, they have formed partnership
with the following groups to reinforce fair and equitable
lending practices nationwide:
• Leadership Conference on Civil Rights (LCCR)
• Association of Community Organizations for Reform
Now (ACORN)
• National Community Reinvestment Coalition (NCRC)
• National Fair Housing Alliance (NFHA)
• National Association of Neighborhoods (NAN)
• Citizens for Community Improvement (CCI)
Argent | Ameriquest has also formed partnerships with numerous
community | national groups in an effort to offer assistance
to victims of predatory lending practices and is proud to
support the efforts of individuals seeking to purchase their
first home.
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