The Compliance Status page in JMAC Connect will display loan-level compliance information once initial disclosures have been sent. The tests on this page include:
- QM Points and Fees
- Higher-Price (HPML)
- High Cost (HOEPA)
- State Rules
The top of the page will display the status of each of these - Pass, Fail, or Not Applicable (N/A). The information below will provide a more detailed breakdown of the key values used in these tests.
Field Definitions
Points and Fees
Reg Z Total Loan Amount - The Regulation Z Total Loan Amount is calculated by the Original Loan Amount/Note Amount minus the finance charges.
Fee Limit % - Allowable fee percentage. Either 3% or 5% depending on loan program.
Fee Limit $ - Allowable fees in dollars. Derived by taking the Fee Limit % of the Reg Z Total Loan Amount.
Total Points and Fees - The total points and fees on this loan.
Difference - The difference between the Total Points and Fees and Fee Limit $. A positive number indicates fees are under the limit and should pass. A positive number indicates the fees are over the limit and should fail.
QM Fees
The QM Fees section provides supporting information for the Points and Fees section.
Lender Fee & Loan Origination Fee - Fees charged by the lender to originate the loan.
Discount Points - The cost to the borrower for the chosen rate. A rebate to the borrower would mean $0 in discount points.
Excludable (Bona Fide) Discount Points - The amount of discount points that can be excluded from the Points and Fees calculation based on the par rate.
Non-Excludable Discount Points - The amount of discount points that cannot be excluded from the Points and Fees calculation.
Originator Compensation - The amount of compensation being paid to the originator.
Higher-Priced (HPML)
Index Date - The date used to determine the Average Prime Offer Rate (APOR).
Average Prime Offer Rate (APOR) - the average APR based on interest rates, fees, and other terms on mortgages offered to qualified borrowers.
APOR Threshold - The dynamic percentage added to the APOR to determine HPML loans. In general, this is 1.5% for first-lien mortgages, 2.5% for Jumbo and Non-QM programs, and 3.5% for second-lien mortgages.
Rate Limit - The rate limit for identifying HPML loans.
Annual Percentage Rate (APR) - The loan's APR, a measure of the interest rate plus additional fees charged with the loan.
Difference - The difference between the APR and Rate Limit. A positive number indicates the APR is under the limit and should pass. A negative number indicates the APR is over the limit and should fail.
State Rules
State rules vary by state. To view the full breakdown of state-specific rules, please download the full compliance report using the link at the top of the page.
High Cost (HOEPA) Points and Fees
Reg Z Total Loan Amount - The Regulation Z Total Loan Amount is calculated by the Original Loan Amount/Note Amount minus the finance charges.
Fee Limit % - Allowable fee percentage of 5%
Fee Limit $ - Allowable fees in dollars. Derived by taking the Fee Limit % of the Reg Z Total Loan Amount.
Total Points and Fees - The total HOEPA points and fees on this loan.
Difference - The difference between the Total Points and Fees and Fee Limit $. A positive number indicates fees are under the limit and should pass. A positive number indicates the fees are over the limit and should fail.
High Cost (HOEPA) Higher Priced
Index Date - The date used to determine the Average Prime Offer Rate (APOR).
Average Prime Offer Rate (APOR) - the average APR based on interest rates, fees, and other terms on mortgages offered to qualified borrowers.
APOR Threshold - The dynamic percentage added to the APOR to determine HPML loans. This is 6.5% for first-lien mortgages and 8.5% for second-lien mortgages.
Rate Limit - The rate limit for identifying HPML loans.
Annual Percentage Rate (APR) - The loan's APR, a measure of the interest rate plus additional fees charged with the loan.
Difference - The difference between the APR and Rate Limit. A positive number indicates the APR is under the limit and should pass. A negative number indicates the APR is over the limit and should fail.
Frequently Asked Questions (FAQ)
Q: Why am I receiving the message, "This page is available after initial disclosures have been sent."?
A: Until initial disclosures are sent, you should use the compliance tests in the Disclosure Generator to determine compliance. The Compliance Status page will continue to provide compliance status after disclosures have been sent.
Q: Why am I receiving the message, "This page is only available when using JMAC disclosures."?
A: The Compliance Status page will be unavailable on correspondent-channel loans that aren't using JMAC disclosures, as we aren't able to properly display the fee and rate information used.
Q: Why am I unable to see the results of certain tests or test information?
A: Certain information is program or channel specific. For example, HPML rules aren't relevant for any of our DSCR programs and Originator Compensation isn't relevant for correspondent-channel loans.
Q: Why does the information on the report download not match the Compliance Status page?
A: The information displayed on the Compliance Status page is pulling directly from the loan, whereas the Compliance Report Download button pulls the most recently run Mavent report. There might be different information on this report depending on when it was run.
Q: How do I fix compliance issues identified on my loan?
A: The fix depends on what test is failing. Most Points and Fees and Higher Priced issues can be resolved by the Lock Desk, who can be reached by email at lockdesk@jmaclending.com or by phone at (949) 390-2687. State Rules issues should be directed to the Disclosures Team at disclosures@jmaclending.com.
Q: Are seller-paid amounts on QM Fees included in the Points and Fees calculations?
A: Seller-paid fee amounts are excluded from these calculations.
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