evaluating borrower creditfic-webinars.s3.amazonaws.com/bc360-04-workbook.pdf · credit score range...

Evaluating Borrower Credit Boot Camp 360 Series Presented by Kimberly Lundquist

Evaluating Borrower Credit - “Boot Camp 360” - Copyright © 2019 FIC Conferences, Inc. 2

Evaluating Borrower Credit Understanding and evaluating a credit report is an essential function in qualifying the borrower. The credit report will provide key information to help the lender decide on the approval or denial of a loan. Let’s start with understanding what credit is and understanding credit scores. What is Credit? Credit is borrowed money provided to the borrower as a loan. This allows the borrower to have the possibility to purchase goods or services when they need them. The money typically comes from a credit issuer, like a Bank or Credit Union, who is then paid back over a certain agreed upon amount of time. Credit usually comes with a finance charge (known as interest) that is paid in addition to the initial amount of money that is borrowed. In most cases, the borrower is required to make a minimum or fixed payment each month that goes toward repaying the debt. What is a Credit Bureau? Credit bureaus package and analyze consumer credit reports from which credit scores are derived. Credit scores are issued as numbers, typically one between 300 and 850. Credit scores can impact the size of a loan a borrower can qualify for and the interest rate charged on the loan, and sometimes even renting and employment opportunities. Although credit bureaus are private companies, they are highly regulated under the Fair Credit Reporting Act, or FCRA. They are limited in how they collect, disburse and disclose consumer information and have come under increased scrutiny since the Great Recession of 2007-2009. There are three primary credit bureaus that are being widely used by lenders. They are Equifax®, Experian® and TransUnion®. Each bureau has a credit score model that they use. What are Credit Scores? What is a credit score, and what is the difference among the 3 credit reporting agency (CRA) credit scores? A credit score is a three digit number, typically between 300 and 850, which is designed to represent the borrower’s credit risk, or the likelihood that they will pay their bills on time. A credit score is calculated based on a method using the content of their consumer file. The way the credit score is calculated and the contents of the consumers file may vary between each of the three national CRAs (Equifax®, Experian®, and TransUnion®). This is because not all creditors report to all three agencies. While most creditors do report to all three, the borrower may hold an account with a creditor that only reports to one, for example, or a creditor that doesn’t report to any. There are many different credit scores used by lenders, including credit scores provided by the national CRAs, and credit scores that are custom built and used by a specific lender.


For the three bureaus, these are the credit score models and credit score ranges that you typically see: • Equifax® - Beacon 5.0 334 - 818 • Experian® - Fair Isaac Risk Model V2 320 - 844 • TransUnion® - Fair Isaac Risk Score, Classic 04 309 – 839

When selling to the secondary market, the GSE’s (Fannie Mae (FNMA) and Freddie Mac (FHLMC)) require these models to be used on the credit reports submitted for selling the loan. These scores are what we know as FICO® scores. Why Lenders Use Credit Scores. Before credit scores, lenders physically looked over each applicant’s credit report to determine whether to grant credit. This process was time-consuming, led to mistakes or biased results, and allowed lenders to make decisions that may have had little bearing on the applicant’s ability to repay debt.

Today, credit scores help lenders assess risk more fairly.

• Credit scores are consistent and objective • They reflect only the likelihood to repay debt responsibly based on the borrower’s past credit

history and current credit status1

What is a FICO® Score? In 1956, an engineer by the name of Bill Fair and a mathematician named Earl Isaac founded FICO, otherwise known as Fair Isaac Corporation. In 1981 FICO introduced the first FICO credit bureau risk score. In 1991, FICO credit bureau risk scores were made available at all three major US credit reporting agencies – BEACONsm at Equifax, EMPIRCA® at Trans Union, and the Experian/FICO model at Experian. In 1995, Fannie Mae and Freddie Mac recommended use of FICO scores for evaluating mortgage loans. In 2009, Fair Isaac Corporation changed the brand name and stock symbol to FICO®. The FICO® Score, available at the three major consumer reporting agencies, helps lenders make accurate, reliable and fast credit risk decisions across the customer lifecycle. The FICO® Score rank-consumers by how likely they are to pay their credit obligations as agreed. The most widely used broad-based risk score; the FICO® Score plays a critical role in billions of decisions each year. The latest US version, FICO® Score 9 is the most current and predictive FICO® Score. The FICO® Score is celebrating more than 25 years of helping people get access to credit quickly and fairly. Introduced in 1989, the FICO® Score changed the lending landscape for good. In the days before credit scoring, people were often denied credit because there was no unbiased structure for evaluating them objectively. The system was not fair, fact-based or consistent.

Enter the FICO® Score. The FICO® Score replaced hunches with calculations, and took prejudice out of the equation, literally. The score’s criteria for evaluating potential borrowers are focused solely on factors related to a person’s ability to repay a loan, rather than one’s ZIP code or social status. This democratization of credit opened the door to an unprecedented period of growth in the U.S. economy.

FICO® is the primary source for credit scores and used by 90% of top lenders with making lending decisions.2

1 Source: experian.com


FICO® used these components to determine the credit score:

• Loan repayment history • Amounts owed • Length of credit history • New credit accounts • Credit applications • Types of credit used

This data is pulled from the credit report and plugged into the FICO® Score formula. The FICO® Score moves up and down as this data changes. The precise FICO® Score at any given moment is a snapshot in time because new data is constantly added to the credit report. The borrower alone has the power to improve their score by consistently paying all their bills on time and managing their credit wisely.3

Here's a breakdown of the five elements of the FICO score:

1. Payment history: 35 percent of the total credit score is based on a borrower's payment history, making the repayment of past debt the most important factor in calculating credit scores.

2. Credit utilization: 30 percent of the total credit score is based on a borrower's credit utilization -- that is, the percentage of available credit that has been borrowed.

3. Length of credit history: 15 percent of the total credit score is based on the length of time each account has been open and the length of time since the account's most recent action.

4 and 5. New credit and credit mix: Each comprise 10 percent of the total credit score.

2 Source: fico.com 3 Source: fico.com


4

How is Credit Utilization Determined? Credit utilization rate, sometimes called credit utilization ratio, is the amount of revolving credit the borrower is currently using divided by the total amount of revolving credit they have available. To put this simply, it’s how much the borrower currently owes divided by their credit limit. It is generally expressed as a percent. For example, if the borrower has a total of $10,000 in credit available on two credit cards, and a balance of $5,000 on one, the credit utilization rate is 50%.

5

4 Source: fico.com 5 Source: experian.com


Credit Score Range Definitions

• 800 +: Indicates an exceptional FICO Score and is well above the average credit score. Approximately 1% of consumers with a credit score of 800+ are likely to become seriously delinquent in the future.

• 740 to 799: Indicates a very good FICO Score and is above the average credit score. Approximately 2% of consumers with a credit score between 740 to 799 are likely to become seriously delinquent in the future.

• 670 to 739: Indicates a good FICO Score and is in the median credit score range. Approximately 8% of consumers with a credit score between 670 to 739 are likely to become seriously delinquent in the future.

• 580 to 669: Indicates a fair FICO Score and is below the average credit score. Approximately 28% of consumers with a credit score between 580 to 669 are likely to become seriously delinquent in the future.

• 579 and lower: Indicates a poor FICO Score and is considered poor credit. A credit score this low could be a result from bankruptcy or other major credit problems. Approximately 61% of consumers with a credit score under 579 are likely to become seriously delinquent in the future.

Per the latest statistics reviewed by FICO the latest Score distribution information based on a snapshot of millions of US consumers’ credit data as of April 2017, FICO can report that consumer credit health and responsibility continue to be strong! For the first time since FICO has been tracking these stats, the average national FICO Score reached the 700 threshold — some 10 points above what it was just prior to the recession in October 2006.6

What Hurts Credit Scores? Certain actions and items can have a greater negative impact on the credit score over other items.

1. Failure to Repay Debt. This can be in several different forms such as: • Missed payments • Charge-off • Collections • Settled accounts-a creditor settles for less than amount owed. • Repossession • Voluntary repossession • Foreclosure • Bankruptcy

2. Credit Use Decisions. Some choices a borrower makes can have a negative effect on their

scores. • Closing accounts-this reduces the total amount of credit available, which can have an

effect on the credit utilization ratio. • Opening new accounts-opening several new accounts in a short period of time. This

can affect credit scores in several ways. There will be several inquiries, along with 6Source: fico.com


new accounts and the possibility of the borrower taking on more debt than they can manage.

• Using only credit cards-this reflects a lack of credit diversity and may affect the score negatively.

3. Public Information. The failure to repay causes several actions and in some cases also show as

public information, such as: • Tax Liens • Civil Judgments • Bankruptcies

What Improves Credit Scores? The borrower can also do things that can help the credit scores.

• Paying bills on time • Paying down debt-this helps the credit utilization ratio • Only apply for credit that they really need

What is a Credit Report? A credit report is a statement that has information about the borrower’s credit activity and current credit situation such as loan paying history and the status of their credit accounts. The lender will use this report to help determine if the loan can be approved or denied. The Credit Report will contain: Personal information

• The borrower’s name and any name they may have used in the past in connection with a credit account, including nicknames

• Current and former addresses • Birth date • Social Security number • Phone numbers

Credit accounts

• Current and historical credit accounts, including the type of account (mortgage, installment, revolving, etc.)

• The credit limit or amount • Account balance • Account payment history • The date the account was opened and closed • The name of the creditor

Collection items


Public records • Liens • Foreclosures • Bankruptcies • Civil suits and judgments

A credit report may include information on overdue child support provided by a state or local child support agency or verified by any local, state, or federal government agency. Inquiries

• Companies that have accessed the borrowers’ credit report. What is a Foreclosure? Foreclosure is when the lender takes back property when the homeowner fails to make payments on a mortgage. Foreclosure processes differ by state. The foreclosure process generally may proceed in one of these ways depending on the state the property is located in:

• Judicial foreclosure. This requires that the process go through a court where the borrower can raise defenses.

• Non-judicial foreclosure. This is done without filing a court action and is carried out by a series of steps, including required written notices under a “power of sale” clause in the mortgage or deed of trust.

Foreclosure processes require that the borrower(s) be notified regarding the proceedings and generally involve giving public notice. State laws on giving notice and scheduling a foreclosure sale vary. Some states may also provide the borrower with the right to mediation prior to foreclosure. What is a Judgment? A judgment is an official result of a lawsuit in court. In debt collection lawsuits, the judge may award the creditor or debt collector a judgment against the borrower. If the borrower does respond to a legal complaint, they will lose their chance to defend themselves and the borrower may find that a judgment is entered against them.7 What is Bankruptcy? Bankruptcy is a process that allows consumers and businesses to repay some or all of their debts under the protection of the federal bankruptcy court. For the most part, bankruptcies can be divided into two types -- liquidation and reorganization. Chapter 7 bankruptcy is called liquidation bankruptcy because the trustee may take and sell ("liquidate") some of the borrowers’ property to pay back some of their debt. However, the borrower can keep property that is protected (or "exempt") under state law. There are several types of reorganization bankruptcies, but Chapter 13 is most commonly used by consumers. In Chapter 13 bankruptcy, the

7Source: CFPB


borrower keeps all of their property, but must make monthly payments over three to five years to repay all or some of their debt.

Both Chapter 7 and Chapter 13 bankruptcy have many rules regarding which debts are covered, who can file, and what property the borrower can and cannot keep.8

Let’s Review the Credit Report. Now that we understand what is provided in a credit report and credit scores, let’s review a credit report and review the items we should focus on. The credit report will answer some vital questions for us, such as:

• How much does the borrower owe? • Is the borrower’s existing mortgage payment current and what the current payment amount is? • Are other existing liabilities current? • Is there previous delinquency? • Are there other major issues such as bankruptcy, foreclosure, liens and judgments? • Does the borrower have too many outstanding liabilities? • Does the borrower have enough credit to determine credit worthiness? • Is the credit history acceptable? • Are there a lot of inquiries and if so has a lot of new debt opened from the inquiries? • What type of debt is the borrower shopping for?

Credit Report Example Next Two Pages

8 Source: nolo.com


9

9 Source: Factual Data


The example credit report that is contained in this workbook is what is referred to as a Tri-merged credit report. This combines the credit histories from all three credit repositories into a single, easy-to-read report. This type of report is very common in the mortgage industry.

Depending on your Institution’s procedures it is vital to actually examine the credit report, whether you are making the preliminary decision or the underwriter is making the decision. Examining the credit report will answer the questions needed to help make a decision or lead you to ask questions and to ask for further documentation or explanations in order to help make the decision.

Examining the Credit Report by Sections Review the names, social security numbers and addresses on the credit report against the application and possible account information that you may have on the borrower if they are your customer. We are not allowed to require any documents from the borrower such as pay stubs, W2’s or bank statements until we have provided the Loan Estimate, however we are able to review if the borrower has the documents with them in a face to face interview. In today’s world, there are a lot of online applications and borrower’s make input errors by transposing numbers or just not remembering birth dates. It is much easier to get the credit report corrected upfront versus in the middle or end of processing.

With a tri-merged credit report the report will reflect credit scores from all three bureaus if the borrower has enough usable credit to determine the score. Review the scores and the factors listed by each score. This will guide you to issues that may need to be addressed within the credit report. When selling to the secondary market they will take the middle score from each borrower and then the lowest of the two middle scores when determining eligibility and pricing. There can be some exceptions to this with manually underwritten loans.


Now we want to review the liabilities on the credit report to verify the current status of each credit account, the timeliness of payments, and the frequency and severity of any delinquent payments. You also want to review how recent or the timing of any delinquent payments.

If there is any derogatory information on the credit report, such as delinquencies, collections, short sale, foreclosure or bankruptcy, then in most cases you will need to ask for a written explanation and/or documentation to support the explanation. Most institutions like for this information to be reviewed prior to processing, however if this is not the case make sure the file is documented prior to submitting to underwriting. Credit histories that have recent delinquent payments (last 24 months) or accounts that were 30,60, or 90 days or longer past due, you need to determine if this was caused by an extenuating circumstance or financial mismanagement. You should review the borrower’s overall credit history including:

• The age of the accounts-Is there a lot of new accounts opened within a short period of time? For example, within last 12 months.

• Credit Utilization-Does the borrower have a lot of revolving debt and the cards are all maxed out?

• Are there several recent inquiries for new debt and what type of debt are they seeking? Are they just shopping for a mortgage or an auto loan or are there inquiries from stores or banks offering more credit cards? Recent inquiries or the presence of a large amount of unrelated inquiries could be an indicator of high risk credit. Someone that is maxed out on credit cards and shopping for more debt could possibly be in financial trouble.


Derogatory information such as bankruptcies, foreclosure, judgments, delinquent payments along with recent inquiries and high credit utilization is an indicator of a high credit risk. All derogatory credit on the credit report should be explained in writing with a letter of explanation (LOE) from the borrower and reviewed with any supporting documentation necessary to document the adverse situation. Review to make sure the mortgages on the credit report match to the mortgages listed in liabilities and/or REO section of the application. A common mistake found is missing an open Home Equity Line of Credit (HELOC) that has a zero balance. The borrower might think nothing of it because they have a zero balance or haven’t used the line of credit in a while; however, this will be an issue if they want to keep the line of credit open. If they want to close the Home Equity Loan request complete information on this loan so a payoff can still be obtained. If they want to keep the Home Equity Loan opened, request the completed information on the loan so that the processor can request a subordination from that lender. If they want a subordination completed, the Loan Officer/Originator should disclose the subordination fee from the Lender holding the Home Equity Loan and make sure that the CLTV and HTLTV are within qualifying parameters. Make sure the liabilities on the credit report match to the liabilities listed on the application. Today we have software that will pull liabilities into the application automatically for us. This does not mean that we should not review. Some liabilities can be duplicated and some omitted from the application in error. Review the liabilities on the credit report for a monthly payment or minimum payment, and the type of account it is. If the credit report doesn’t reflect a minimum payment for the liability, you will want to make sure a payment is entered on the application. Secondary market guidelines require a 5% payment calculation of the outstanding balance. Sometimes this 5% calculation could make debt-to income ratios too high, therefore it is a good business practice to request a copy of the monthly statement and use the actual minimum payment. Payments on installment loans with 10 months or less can be excluded from the debt to income ratio calculation. Student loans or other installment loans in deferment still need to be calculated into the debt to income ratio calculation. You will want to obtain documentation verifying the monthly payment amount. If the student loan payment cannot be documented 1% of the outstanding balance can be used for qualifying purposes. Auto lease payments are included in debt to income ratio regardless of the remaining term. In reviewing the credit report, you will notice that you are able to review the following:

• Creditor/Lender • When the account was opened • What the last reported date on the account was • The High Balance and High Limit • How many months the account has been reviewed on the credit • How many times the borrower has been 30,60, 90 or more days delinquent and dates is

applicable • If the borrower is currently past due • What the monthly payment is • The current balance • When the account was last active • What credit Bureaus the account is being reported to


• What type account the liability is (installment, revolving, open, etc.) • If the account is opened or closed • Mortgages sold to Fannie or Freddie are usually reflected • If an auto liability is an auto lease

Generally, inquiries reflect back for at least 90 days. You want to review to see if there are any inquiries that need to be addressed? If so, you usually need to request a written signed explanation from the borrower regarding these inquiries? If any accounts were opened from the inquiries and they are not being reported to the Credit Bureau request documentation from the borrower reflecting current balance and payment information.

Creditor Information is listed usually providing an address, phone number or both for creditors reporting to the credit bureau, providing some contact information for you.

The credit report usually provides a summary of the borrower so that you can see at a quick glance, late payments, number of accounts, payment summaries, balances owed, amounts past due and high credit/balance.


The Oldest tradeline date helps you determine how long the borrower has had established credit. This is important because you want to make sure that this corresponds to the borrower’s age.

Public Records will reflect information reported to the credit repository databases that includes bankruptcies, judgements and tax liens.

Residence Information will provide a listing of current and past residence records for the applicant and co-applicant if applicable, that has been reported to the credit bureaus. This provides the opportunity to question any addresses appearing that does not match to application or other documentation.

Employment information that has been reported to the credit bureaus will also be listed. This will reflect current and past employers for the borrower’s. Verify this information against the application for any discrepancies.

Alternate names are also usually reflected on the credit report. These are usually other names used when obtaining credit. This can be useful in helping you to determine other names used (aka’s) for s signature name affidavit, however be careful here because a name could be listed that was a typo for the creditor pulling credit and may not really be a name that the borrower uses.


What’s New? Trended Credit-What is it? Trended credit data will provide up to 24 months of historical data for some tradelines and reflect the historical data on the borrower’s credit behavior. The information provided will include balance, credit limit, high credit, scheduled payment and actual payment. Trended credit data is FCRA-regulated and is disputable. Trended Credit-Why? In 2015 Fannie Mae announced that they would start requiring lenders to use trended credit data when submitting loans for automated underwriting through Desktop Underwriter® (DU) in 2016. Due to this trended data policy from Fannie Mae, Equifax and TransUnion have replaced the current credit report for mortgage origination with new products that include trended credit data. Experian’s trended credit data may be included in the future. Per Fannie Mae, the addition of trended credit in underwriting decisions will not impact Approve/Eligible recommendations percentages. Fannie Mae states this will provide a more precise credit risk analysis. Another benefit Fannie list is that trended credit will allow lenders to determine if the borrower pays off revolving credit each month, or only makes minimum payments and carries a balance month to month. Freddie Mac is still studying trended credit data and its impact on the Borrower’s creditworthiness and Mortgage performance, therefore they have not incorporated trended credit into their Loan Product Advisor. VantageScore Credit Score Model VantageScore is a product of VantageScore Solutions, an independent company formed by the three major credit bureaus, Equifax, Experian, and TransUnion. VantageScore was created in the mid-2000’s and is becoming used fairly widely. This model was developed to increase scoring consistency across bureaus. A key distinction between VantageScore and competing developers is the fact that VantageScore credit scoring models operate identically on data from all three national credit reporting companies (CRCs—Equifax, Experian and TransUnion). Competing developers tailor their models to each CRC’s database, an approach that introduces an inherent degree of inconsistency to the scoring process. The result is an unclear determination of risk. VantageScore employs a single, uniform model and a patented characteristic leveling process to treat pieces of data from each CRC the same. That means less variation in scores pulled simultaneously from


multiple CRCs. It also means those variations can be chalked up to differences in credit-file content, rather than the scoring process itself.10 The VantageScore changed the scoring structure to include millions of additional consumers who were previously unscored by other models. The VantageScore places a heavier emphasis on age of accounts than FICO models and incorporates payment information from other sources, like utility companies. What is the National Consumer Assistance Plan (NCAP)? In March of 2015, Equifax, Experian and TransUnion launched the National Consumer Assistance Plan (NCAP), in order to make credit reports more accurate and to make it easier for consumers to correct any errors on their credit reports. The plan was launched after cooperative discussions and an agreement with New York Attorney General Eric Schneiderman and a group of other State Attorney General’s stimming from an investigation of the credit bureaus launched by Schneiderman. Schneiderman had received numerous complaints about how difficult it was for consumers to fix errors on credit reports and medical debts being reported on credit reports too quickly. The three companies are taking a number of steps to improve data accuracy and quality and make it easier for consumers to understand their credit information. The companies are implementing the plan over a three year period with full implementation of the plan expected by March 2018. Changes included in the National Consumer Assistance Plan include:

• Consumer experience: o Consumers visiting www.annualcreditreport.com, the website that allows consumers to

obtain a free credit report once a year will see expanded educational material. o Consumers who obtain their free annual credit report and dispute information resulting in

modification of the disputed item will be able to obtain another free annual report without waiting a year.

o Consumers who dispute items on their credit reports will receive additional information from the credit reporting agencies along with the results of their dispute, including a description of what they can do if they are not satisfied with the outcome of their dispute.

o The credit reporting agencies (CRAs) are focusing on an enhanced dispute resolution process for victims of identity theft and fraud, as well as those who may have credit information belonging to another consumer on their file, commonly called a “mixed file.”

• Data accuracy and quality: o Medical debts won’t be reported until after a 180-day “waiting period” to allow

insurance payments to be applied. The CRAs will also remove from credit reports previously reported medical collections that have been or are being paid by insurance.

o Consistent standards will be reinforced by the credit bureaus to lenders and others that submit data for inclusion in a credit report (data furnishers).

o Data furnishers will be prohibited from reporting authorized users without a date of birth and the CRAs will reject data that does not comply with this requirement.

o The CRAs will eliminate the reporting of debts that did not arise from a contract or agreement by the consumer to pay, such as traffic tickets or fines.

10 Source: vantagescore.com

http://www.annualcreditreport.com/


o A multi-company working group of the nationwide consumer credit reporting companies has been formed to regularly review and help ensure consistency and uniformity in the data submitted by data furnishers for inclusion in a consumer’s credit report.11

Conclusion Now that you have an understanding on how to read a credit report, this will allow you to ask the necessary questions upfront and possibly avoid a delay in closing or the possibility of the loan being denied in final underwriting. This will also help provide you some assistance on how to explain credit to borrowers and ways to improve credit or avoid making bad credit decisions. Help educate your borrower’s.

11 Source: nationalconsumerassistanceplan.com


Quiz

1. What does the acronym FCRA stand for? a. First Credit Reporting Agency b. Federal Credit Reporting Agency c. First Credit Reporting Administration d. Fair Credit Reporting Act

2. FICO is a registered trademark of?

a. Federal International Corporation b. Fannie’s Initiative Corporation c. Fair Isaac Corporation d. Freddie’s Insurance Corporation

3. What is NOT a component used by FICO to determine the credit score?

a. Payment History b. Zip Code c. Credit Utilization d. New Credit

4. What percentage of the FICO score comes from credit utilization?

a. 30% b. 35% c. 15% d. 10%

5. What percentage of borrowers with credit score ranges from 670 to 739 are likely to become

seriously delinquent in the future? a. 1% b. 2% c. 8% d. 10%

6. What is NOT included on a Credit Report?

a. Birthdate b. Phone Numbers c. Credit Accounts d. Criminal Record

7. Which item does NOT improve credit scores?

a. Paying bills on time b. Paying down debt c. Only apply for credit needed d. Have credit cards only from high end department stores


8. How many bureaus does a tri-merged credit report pull information from?

a. 2 b. 3 c. 1 d. 4

9. What percentage of payment should you indicate on a liability that is not reflecting a minimum

payment on the credit report? a. 5% b. 4% c. 3% d. 2%

10. How many days back are inquiries usually reported on the credit report?

a. 30 b. 45 c. 60 d. 90

Congratulations! Now that you have completed this short quiz for self-assessment, please check with your administrator for the answer key along with your Certificate of Completion! For your convenience, we have already sent these to the person who signed up your Institution for this Boot Camp 360 Training. You are also welcome to send us your name, email and contact information and we will happily send you the answer key along with your Certificate of Completion! [email protected]


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This manual is broken down into sections to cover each of the federal regulations that effect Closed-end Residential Real Estate Lending and Compliance with those regulations. As part of the Alliance, you will receive this manual and automatic updates for one full year! In addition you will have complete access to the manual on-line 24/7! So basically you get the manual absolutely FREE!

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Thank you for your participation! Please contact us if you have any questions or need assistance. We want to be “Your Partner in Compliance!” Email if you have questions concerning the information provided! Thank you for your business and we look forward to hearing from you again soon! Kimberly Lundquist [email protected] FIC Conferences, Inc. 1150 N Loop 1604 W Suite 108-603 San Antonio, TX 78248 Tel 210-493-1761 Fax 210-493-9659 www.ficconferences.com

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