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Posted by Bear900/CA on 9/24/21 1:47pm
One of the things I enjoyed most about being an NSA when I started loan origination was comparing what other lenders (not LOs) were doing differently, and figuring out why, perhaps even adapting, which I am open to doing.
OTOH, they may be totally wrong. While adaptable I'm not easily led astray. But I have a lot of questions as an originator.
1. OP says, "a particular lender..." not an LO or processor, wants both borrowers to initial the same spot. Hmm..
2. "Your initials._____ ", in both areas." What does this mean? Sorry OP, this is insufficient information.
3. OP doesn't provide enough information about the app which is to be expected. Our expertise doesn't go into how to complete it. We just know that it's joint. Is that sufficient? Joint apps can be completed and printed in different manners.
4. What's going on in their compliance department to make this adjustment if it's not a mistake? Something we'll never know, so why the big hoopla?
5. Were there distinct instructions for both borrowers to initial in the same place? OP doesn't make that clear. If so...
6. What do we know about the original 'intent' of having those initials? That's perhaps the best starting point when something is unclear. Spoil alert, there exists a lot of government Code to go through. Up for that?
7. Have you thought about picking up the phone and calling the LO who's name and ph number is on the 1003 and saying something like: "I noticed your bank gave specific instructions to have both borrowers initial the joint credit box. I'm trying to obtain a better understanding and increase my knowledge as a NSA. Would you mind if I passed this information on to others in my trade?"
8. If the feds allow lenders to modify 1003s such as adding signatures and initials on various pages is this also allowable? IDK...
I understand we are only concerned about where to sign and initial. Well, there you have it. The new URLA is still just that, new. |
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