26.01.2015 Views

Uniform Residential Loan Application (1003) Red Flags

Uniform Residential Loan Application (1003) Red Flags

Uniform Residential Loan Application (1003) Red Flags

SHOW MORE
SHOW LESS
  • No tags were found...

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

Welcome to PMI’s On-Demand Training Bootcamp<br />

<strong>Uniform</strong> <strong>Residential</strong> <strong>Loan</strong><br />

<strong>Application</strong> (<strong>1003</strong>)<br />

<strong>Red</strong> <strong>Flags</strong><br />

PRESENTED BY<br />

PMI MORTGAGE INSURANCE CO.<br />

•Welcome to PMI’s Training BootCamp, the <strong>Uniform</strong> <strong>Residential</strong> <strong>Loan</strong> <strong>Application</strong> <strong>Red</strong> <strong>Flags</strong><br />

module.<br />

•The FBI reports that one in every ten mortgage loans is obtained on fraudulent information,<br />

and estimates that 20% of all credit loss within the mortgage industry is a result of fraud.<br />

•Historically, the loan application contains the highest percentage of fraud in a mortgage loan<br />

file, which is why it so important to conduct a thorough review and analysis of the <strong>Uniform</strong><br />

<strong>Residential</strong> <strong>Loan</strong> <strong>Application</strong> (<strong>1003</strong>).


Agenda<br />

• Purpose of the <strong>Uniform</strong> <strong>Residential</strong> <strong>Loan</strong> <strong>Application</strong> (<strong>1003</strong>)<br />

• Identify Mortgage <strong>Application</strong> <strong>Red</strong> <strong>Flags</strong><br />

• Identify Fraud Schemes associated with the <strong>1003</strong><br />

1<br />

•We’ll start with an overview of the purpose of <strong>1003</strong> and it’s importance in evaluating the<br />

mortgage loan file.<br />

We’ll review the <strong>1003</strong> to identify where common red flags reside and how to catch them.<br />

•Along the way we’ll provide you with some job aids that you might find useful in your<br />

endeavor to identify red flags.<br />

•And finally, we’ll discuss the prevalent fraud schemes that are specific to the <strong>1003</strong>.<br />

•Before we start the session, I’d like to provide a few tips on how to navigate through this<br />

module.


What is the <strong>Uniform</strong> <strong>Residential</strong> <strong>Loan</strong> <strong>Application</strong><br />

• GSE Standardized Form<br />

• Also known as:<br />

• Fannie Mae Form <strong>1003</strong> (7/05)<br />

• Freddie Mac Form 65 (7/05)<br />

• Handwritten <strong>Loan</strong> <strong>Application</strong><br />

• Final, Typed <strong>Loan</strong> <strong>Application</strong><br />

2<br />

•The <strong>Uniform</strong> <strong>Residential</strong> Mortgage <strong>Application</strong>, commonly referred to as the <strong>1003</strong>, is used to establish a profile<br />

of the borrower. All documents in the file should support the information contained in the application. You need to<br />

look at the individual aspects of the loan as well as the loan in total for consistency and reasonableness as part<br />

of the underwriting decision. If an application has omissions, request the missing information. If the application<br />

includes inconsistent or questionable information, ask follow-up questions to get to clarify the situation.<br />

•The <strong>Uniform</strong> <strong>Residential</strong> <strong>Loan</strong> <strong>Application</strong> is a form that was standardized by the GSEs, Freddie Mac and<br />

Fannie Mae, and is the required format for obtaining necessary information from mortgage loan applicant(s).<br />

•It is often referred to as the <strong>1003</strong> because this is the Fannie Mae form number. Freddie Mac uses the same<br />

form; however, their form number is 65. The 7/05 version is the most recent and has modifications which reflect<br />

some underwriting advances to help make the form more user-friendly than prior versions.<br />

•There are two versions of the loan application that will require review.<br />

•The first is the initial handwritten application. <strong>Loan</strong> officers are expected to submit a complete and accurate<br />

application. Even omissions as simple as education level or dependent information can affect an underwriter's<br />

ability to establish an accurate borrower profile.<br />

•A final version is also created reflecting verified information and submitted with the loan application to the<br />

underwriter.<br />

•One way to catch red flags is to cross-check the information on the initial, or what is commonly referred to as<br />

the handwritten application, against the final or typed application.<br />

•Again, a large percentage of fraud occurs in the mortgage application; therefore, it is important to not only<br />

validate the information on the mortgage application but to cross-check the information against information on<br />

other verification sources in the loan file.


<strong>1003</strong> Fraud Statistics<br />

Escrow/Closing<br />

Docs<br />

10% Credit Report<br />

VOE<br />

4%<br />

15%<br />

VOD<br />

21%<br />

<strong>Application</strong><br />

61%<br />

Appraisal/Value<br />

22%<br />

Tax<br />

Return/Financial<br />

Statements<br />

28%<br />

3<br />

•We pulled some statistics from the Eleventh Periodic Mortgage Fraud Case Report To the<br />

MBA published in March 2009. The statistics include data reported in 2008.<br />

•The largest percentage of fraud occurs in the loan application; therefore, completion, review<br />

and analysis of the <strong>1003</strong> should be taken very seriously.


Role of the Originator<br />

• Consult, instruct & guide<br />

• Obligations<br />

4<br />

•From the first point of contact, it is our responsibility as loan originators, loan coordinators,<br />

and loan processors<br />

•To consult, instruct and guide the applicant(s) to ensure that precise,<br />

comprehensive and truthful information is obtained from, and given to, the mortgage<br />

loan applicant(s).<br />

•We have an obligation to the customer, our company, and the industry as whole, to do our<br />

part, and to do it well.


What if I use an automated system<br />

• AUS systems don’t replace verification<br />

• The <strong>1003</strong> provides a “blueprint”<br />

• Originator is ultimately responsible for data accuracy<br />

5<br />

•Origination systems are a great tool. They do not, however, negate the use of the <strong>1003</strong> and<br />

other verifications to render a loan decision.<br />

•Don’t use the AUS system as the exclusive analytical tool for underwriting the loan. Keep in<br />

mind, garbage in, garbage out. You should analyze the information on the <strong>1003</strong> to ensure<br />

that it makes sense, especially in instances where discrepancies will not be caught by an<br />

automated system.<br />

•Many of you may be utilizing AUS systems; however, these systems do not replace the<br />

<strong>1003</strong>. Use the <strong>1003</strong> as your base for information. The <strong>1003</strong> provides a detailed plan or view<br />

of the applicant’s financial situation.<br />

•The loan originator is ultimately responsible for the accuracy and validity of the data you<br />

input into an automated system, so make sure you know and understand the data.<br />

•If you originate/ process within your company’s loan origination system, it is important that<br />

you become knowledgeable on how these fields cross-reference or populate the <strong>1003</strong> to<br />

accurately represent the applicant’s information.


Identifying <strong>1003</strong> <strong>Red</strong> <strong>Flags</strong><br />

IDENTIFYING <strong>Red</strong> <strong>Flags</strong><br />

Guidelines for Fraud Review<br />

Pre-Closing <strong>Red</strong> <strong>Flags</strong> Checklist<br />

6<br />

•Now let’s put the theory into practice.<br />

•We’ll review various loan documentation and point out the more common areas of where<br />

you might catch red flags.<br />

•We can’t catch all of the potential red flags; however, PMI has a checklist that identifies preclosing<br />

red flags. You can click on the link in this slide to view the Pre-Closing <strong>Red</strong> <strong>Flags</strong><br />

Checklist.<br />

•Keep in mind that our red flag document review will not be comprehensive, the main<br />

objective is to train your eye to “SEE” the information and check for reasonableness and<br />

soundness, and to seek additional information or explanation where potential discrepancies<br />

are noted. If the data does not make sense, ASK a question.<br />

•While much of what we’re going to talk about seems elementary, we’re often surprised at<br />

how even seasoned underwriters miss this information.<br />

•Go ahead and pull out the Pre-Closing <strong>Red</strong> <strong>Flags</strong> Checklist and check off any red flags we<br />

encounter along the way.<br />

•Let’s start our review.


Mortgage <strong>Application</strong>s<br />

Pre-Closing <strong>Red</strong> <strong>Flags</strong> Checklist<br />

7<br />

•There are two sections of the checklist that should be referenced when reviewing the loan application.<br />

•The first is ‘Section I’ or the <strong>Loan</strong> File <strong>Red</strong> <strong>Flags</strong> section. This section will pertain to every aspect of the loan file<br />

since it identifies where inconsistencies exist while cross-referencing loan documentation.<br />

•The second is section 2 or the ‘<strong>Loan</strong> <strong>Application</strong> <strong>Red</strong> <strong>Flags</strong>’.


Handwritten Mortgage <strong>Application</strong><br />

8<br />

•The mortgage application will allow you to develop a profile of your borrower or borrowers.<br />

Your job is to determine if the information makes sense based on the borrower’s profile.<br />

•Many inconsistencies and/or misrepresentations can be identified at this stage by analyzing<br />

basics such as:<br />

•Differences in the handwriting and signatures<br />

•Date inconsistencies and<br />

•Employment and income inconsistencies<br />

•Let’s take a look at Gail Owning’s handwritten <strong>1003</strong> for any potential red flags.


Handwriting <strong>Red</strong> <strong>Flags</strong><br />

9<br />

•We’re looking at the employment section of the <strong>1003</strong>. Take a moment to see if you can<br />

identify where there are differences in handwriting.<br />

•Once you’re done, move to the next slide.


Consistent Handwriting – Employment Section<br />

10<br />

•Did you identify the SS# or the zip code<br />

•As you can see, it can be somewhat difficult to identify different handwriting; you have to<br />

really LOOK at the information. You’ll find that something as simple as varied handwriting<br />

can be a very telling red flag.<br />

•Note the differences in how the numbers are written. For instance, the number 9 in the SSN<br />

box and the years at current address are very different. The number 7 in the zip code and<br />

the social security number are also very different.<br />

•There could be many reasons for this. We should keep in mind however, that false SSN’s<br />

could mean identity fraud. We’ll want to keep our eyes open for any other possible signs of<br />

this type of fraud.<br />

•Now let’s take a look at the asset section.


Consistent Handwriting – Assets Section<br />

11<br />

•Before you advance to the next slide, look for any inconsistencies in handwriting on the<br />

assets and liabilities sections of the handwritten application.


Consistent Handwriting – Asset & Liabilities Sections<br />

12<br />

•It appears that the name of the bank, Bank of ConnTrust is in the same handwriting;<br />

however, the amount in the bank differs. This should now be a red flag that alerts you to pay<br />

special attention to the asset verifications. This may be an issue because the borrower may<br />

not have had sufficient funds to qualify and you want to determine whether they may have<br />

sought funds from an unacceptable source that is not being disclosed but were deposited<br />

into a bank account. In order to ‘hide’ the fact that these funds were from an unacceptable<br />

source, the handwritten application may have been modified to make it appear the borrower<br />

had these funds in savings.<br />

•All of the liabilities information appears to be different handwriting. The borrower should be<br />

encouraged to list all of debts on the handwritten application in order to identify any<br />

inconsistencies when verifying their credit history. In some cases, you may notice that this<br />

information is completed after the credit report is obtained. This practice should be avoided<br />

as debts may be missed or hidden if the debt, for whatever reason, is not listed on the credit<br />

report.


“Squeezed-in” Information<br />

13<br />

•Another clue that information may have been completed after the initial application was<br />

taken is if the information is “squeezed-in” or whited-out.<br />

•Let’s go back to the first page of the <strong>1003</strong>, the borrower’s information section. Take a few<br />

seconds to determine if you see any information that is squeezed in.<br />

•We were already alerted to the fact that the SSN# appears to be written in different<br />

handwriting; it also appears to be larger and squeezed into the SSN# box, further<br />

emphasizing that this information may have been entered after the initial application was<br />

taken.


Date Inconsistencies – Employment Section<br />

14<br />

•A significant amount of misrepresentation can be detected through inconsistent dates.<br />

Review all of the dates and ask yourself if they make sense. Check the employment history<br />

and the assets sections. Check that the handwritten application was completed prior to the<br />

verifications.<br />

•Let’s take a look at Gail’s employment history to determine if the dates match up. Gail has<br />

been on her current job for only eight months meaning that she should have provided her<br />

prior employment history. GSE guidelines indicate that we need to verify a 2-year consistent<br />

and stable employment history. We talk more about the income and employment consistency<br />

in a moment, so let’s focus only on the dates now.<br />

•Gail has been at her job for eight months.<br />

•Now let’s look at her prior employment history to determine if there are any gaps in<br />

employment that would cause concern.<br />

•She had two jobs prior, both from the timeframes of 9/06-6/08, which could in and of itself be<br />

a red flag. If we count eight months from 6/08, the employment dates for her current<br />

employment should be approximately 6/08 – 2/09. Does this make sense from the date the<br />

application was taken


Date Inconsistencies – Signature Section<br />

15<br />

•Let’s take a look at the date the application was taken.<br />

•Gail signed the application on 3/15/09.<br />

•Take a moment to think about whether or not this makes sense, then answer the next<br />

question.


Question – Date Inconsistencies<br />

• The prior employment dates are consistent with the current<br />

employment date.<br />

• True<br />

• False<br />

16<br />

•Correct answer: True


Date Inconsistencies – Employment vs. Signature<br />

17<br />

•Remember that Gail’s prior job history states she was employed from 9/06 to 6/08. She has<br />

been on her current job for 8 months. If we assume that she started her current job right<br />

after she ended employment on her prior job, the dates of her current job would support<br />

employment from 6/08 thru 2/09. This seems consistent with the 3/09 signing of the<br />

application.<br />

•These are the dates you should expect to see on the verifications of employment.


Date Inconsistencies – <strong>Loan</strong> Officer Signature<br />

18<br />

•Lastly, let’s compare the date the borrower signed the application to the date the loan<br />

interviewer, typically the loan officer, signed the application.<br />

•We see that Gail signed the application on 3/15/09.<br />

•The interviewer dated the application the same date. Ask yourself whether the date spread<br />

makes sense based on how the interviewer took the application. In this case, the interviewer<br />

took the application over the phone. If that were the case, most likely all of the handwriting<br />

on the application, with the exception of the borrower’s signatures, would be the same as that<br />

of the interviewer. Most likely the date the borrower signed and the date the interviewer took<br />

the application would vary as the application would either need to be hand-carried or mailed<br />

for the borrower’s signatures. If the application was taken face-to-face, the same dates<br />

would make sense.<br />

•Also notice that the interviewer did not sign the application, which is a requirement.


Date Inconsistencies<br />

<strong>Loan</strong> Officer vs Borrower Signature<br />

19<br />

•The borrower, Gail, did sign the application. As you review the file it is important to crosscheck<br />

her signature against other verifications in the loan file.<br />

•The interviewer did not sign the application as required. In addition, you’ll notice that they<br />

placed the date where the interviewer’s name should have been written. This could be an<br />

honest mistake; however, keep in mind that these are the very basic kinds of errors that<br />

fraudsters make. They often forego attention to detail when forging documentation.


Employment & Income History<br />

20<br />

•It’s time to stretch our analytical minds a bit further. We’ve reviewed areas that may provide<br />

physical clues leading to red flags.<br />

•Let’s now delve deeper into the data to determine if the scenarios seem reasonable based<br />

on the borrower’s profile as presented on the loan application.<br />

•We’ll start with Gail’s employment history. You should take into consideration Gail’s age and<br />

years of school to determine if they support her current employment and income history. We<br />

see that Gail is about thirty-two and appears to have a high school diploma; at least we know<br />

she has completed twelve years of school.<br />

•She has listed her current employment as an office manager. Generic job titles can be an<br />

indication of a red flag. Gail’s title is stated is an example of a generic job title, so we’ll<br />

identify it as a red flag.<br />

•Let’s determine if her prior employment history supports that of an office manager.<br />

Remember she had two prior jobs within the same timeframes; meaning that it appears that<br />

she had a first and second job.<br />

•She worked as a teacher’s aid and owned her own cleaning company at the same time.<br />

These two jobs are unrelated, which may not be an issue; however, neither support her<br />

current position as an office manager. They all require different skill sets. Again, this isn’t<br />

impossible; however, it is a potential red flag. Let’s flag the prior employment history and<br />

take a look at the income history to see if that gives us any additional clues to potential red<br />

flags. Remember, the income history should be supported by the borrower’s position and<br />

employment history.<br />

•Take a moment to think about all of the red flags associated with Gail’s income and<br />

employment history, then answer the next question.


Question: Employment & Income History<br />

• There are three notable red flags concerning Gail’s employment history.<br />

Which of the following items is NOT a red flag.<br />

A. Gail’s current income of $8,620 seems high for her current position of office<br />

manager<br />

B. Gail’s prior income of $8,600 per month seems high for her position of<br />

teacher’s aid<br />

C. Gail’s dates of employment are not consistent<br />

D. Gail’s prior self-employment is consistent with and supports her current<br />

position<br />

21<br />

•Correct answer: C<br />

•[Feedback] The dates of employment are consistent; however, the level of income, positions<br />

and the fact that she had two highly paid jobs at the same time are questionable.


Employment & Income History Review<br />

22<br />

•We see that Gail’s base monthly income for her current job is $8,620. This seems quite high for an office<br />

manager; again, it’s possible; however, does it make sense Salaries are often commiserate with experience,<br />

skill level, job responsibilities and education. Let’s flag this as a potential red flag and review her prior income<br />

history and see if we change our mind.<br />

•Gail states she made $8600 a month as a teacher’s aid; this level of income for a teacher’s aid is not<br />

reasonable and should cause you to question the income. Especially if you consider that Gail was operating her<br />

cleaning business along with this job. One might assume that this was a second, probably part-time job. We’ll<br />

put a red flag here.<br />

•Gail also indicates that she owned her own cleaning business. At this point, we don’t have any financials on the<br />

business to judge whether or not this income makes sense; however, there are some questions that immediately<br />

come to mind:<br />

•If Gail was making $14,425 a month, why have a second job It’s possible she loves children and her<br />

employment was more about personal enjoyment than financial gain; however, the level of income for<br />

the business would seem to indicate a considerable investment in her time with less spare time for a<br />

second job that would generate an additional $8,600/mo. We’ll put a red flag here.<br />

•Also, why did Gail end her business as she was making considerably more money at her own<br />

business than her current position<br />

•Why did Gail stop working with Children’s Garden<br />

•There may be reasonable explanations to one or more of these questions; however, combined they<br />

don’t seem to make sense.<br />

•We can look deeper into Gail’s financial profile to determine if her assets and credit support the income level<br />

reported in the Employment & Income <strong>Red</strong> <strong>Flags</strong> module.<br />

•Let’s start with the assets section.


Assets <strong>Red</strong> <strong>Flags</strong><br />

$23,000/mo<br />

23<br />

•Before we even look at the assets section, we can develop some expectations of what we<br />

may find there based on the borrower information, employment and income sections.<br />

• We know that Gail has been working for at least the past two and a half years. Eight months<br />

ago, and for almost two years consecutively, she was earning approximately $23,000 a<br />

month. That’s assuming her starting salary with Children’s Garden and A+ Cleaning Services<br />

was consistent with her ending salaries.<br />

•We should expect to see substantial assets, assuming her expenditures were low. We’ll<br />

analyze her liabilities once we’re finished with the assets section.


Consistent Assets<br />

$23,000 = income<br />

- 7,600 = taxes<br />

- 1,950 = housing<br />

- 30 = debt<br />

- 2,000 = misc<br />

= $11,000 = net income<br />

x 12 = $132,000/yr<br />

24<br />

•Gail’s assets consist of the escrow deposit of $5,000 and $40,000 in a bank account.<br />

•You should ask yourself if this seems reasonable<br />

•Let’s put this into perspective by analyzing some numbers.<br />

•Gail’s monthly income was approximately $23,000 for both jobs over the past two years.<br />

•Let’s reduce this income by taxes and expenses:<br />

•Let’s consider 33% for taxes, which is approximately $7,600/mo<br />

•<strong>Red</strong>uce this amount by her housing expense of $1,950/mo<br />

•<strong>Red</strong>uce this amount by the $30 a month in debt she indicates in the liabilities<br />

section.<br />

•Then let’s take a generous $2,000 a month for other living expenses and incidentals.<br />

•The net amount is $11,000, rounded down from $11,420.<br />

•This totals $132,000 per year after expenses; and remember that Gail potentially<br />

earned this amount over two and a half years. However, Gail has only $45,000 in<br />

savings<br />

•Our next assumption may be that she is spending a considerable amount if she is not saving<br />

it.<br />

•We can look to her non-liquid assets to determine what other types of assets Gail has that<br />

may answer some of our questions.


Non-liquid Assets<br />

$132,000/yr<br />

x 2.5 = $330,000<br />

25<br />

•Gail’s non-liquid assets consist of a ’99 Mercedes and some furniture and jewelry for a total<br />

of $100,000 in non-liquid assets. Keep in mind that this information is subjective and will not<br />

be verified. Again you’re looking for reasonableness; assuming that the information is<br />

accurate…<br />

•Remember that Gail’s residual income after expenses for one year was $132,000 and we<br />

have verified a two and a half year history. $132,000 times 2.5 yrs would amount to<br />

approximately $330,000 in residual income over two and a half years.<br />

•It’s possible that Gail didn’t list some assets. She might spend a considerable amount of her<br />

income on ‘stuff’ or some of the information listed on the application might not be accurate.<br />

•Given that the ratio of assets to savings potential is low, we’re going to flag this.<br />

•Remember the more red flags in a file the greater the potential for fraud. We’ve<br />

accumulated quite a few red flags and we’re not even finished reviewing the handwritten loan<br />

application yet.<br />

•Now let’s look at the liabilities section.


Liabilities <strong>Red</strong> <strong>Flags</strong><br />

26<br />

•I’ve already mentioned that Gail listed only one liability, which means she has minimal outgo<br />

to liabilities.<br />

•The minimal use of credit also does not seem in line with her employment and income<br />

history. She owned a company and her income was sizeable so you’d expect to see more<br />

credit cards with potentially high credit limits. We’ll analyze her credit report in the Social<br />

Security Numbers and Credit Reports <strong>Red</strong> <strong>Flags</strong> module, but so far this appears to be a red<br />

flag.<br />

•This completes our review of the handwritten <strong>1003</strong>. Our mission now is to cross-reference<br />

this information for consistency and reasonableness with the final typed <strong>1003</strong>, paying special<br />

attention to those areas where we may have raised red flags.


Final, Typed Mortgage <strong>Application</strong><br />

27<br />

•The final, typed <strong>1003</strong> is completed by the loan processor after all of the verifications have<br />

been obtained and is submitted with the loan file for underwriting.<br />

•One of the objectives in reviewing the final application is to determine if there are material<br />

differences between the handwritten application, the information the borrowers supplied, and<br />

the final typed application which is based on the verified information.<br />

•We’ll focus only on key areas of the application; however, your review should be detailed,<br />

comparing all fields of data between the initial and final applications.<br />

•Let’s start with the employment and income section.


Final, Typed Mortgage <strong>Application</strong><br />

• Significant changes in employment/income<br />

28<br />

•Are the dates of employment consistent Match the verified dates of employment to<br />

the dates provided on the initial application.<br />

•Is the verified income consistent with the information on the initial application and<br />

does it make sense<br />

•In this case the information on the final, typed application is exactly the same as the<br />

information on the final application. While we want consistency, the fact that the<br />

information is exactly the same could be red flag.<br />

•Another key area to review is the assets section. Let’s take a look.


Consistent Assets<br />

29<br />

•Are the assets stated on the final application consistent with the initial application<br />

•If not, you may need to conduct more research or obtain additional documentation<br />

to determine if an increase in assets is from a verifiable acceptable source.<br />

•In other words, you want to ensure that the borrower didn’t borrow funds from an<br />

unverified source.<br />

•In this case the assets on the final application are exactly the same as the initial<br />

application.<br />

•I also want to point out that the amount of assets in Bank of ConnTrust end in a<br />

round number. The percentages of this happening are very low, so this may also<br />

indicate a red flag. We’ll talk more about why round numbers are indicative of a red<br />

flag in the Employment and Asset <strong>Red</strong> <strong>Flags</strong> module, but for now let’s flag it.


Consistent Liabilities<br />

30<br />

•Now let’s review the liabilities.<br />

•Again, you notice that the liabilities on the final application are exactly the same as<br />

what was stated on the initial application.<br />

•Since the final application represents the verified information, the liabilities also<br />

match exactly what was on the credit report.<br />

•In this case we have only one liability; however, if you had more than one you<br />

should check the order in which the liabilities are listed.<br />

•In addition, check the amounts of the unpaid balances. If they are exactly the same<br />

it is a red flag, so we’ll flag it.


Final, Typed Mortgage <strong>Application</strong><br />

Date Inconsistencies<br />

31<br />

•Finally, let’s look at the dates.<br />

•Remember, that dates can trip up fraudsters and can be an effective way to identify<br />

red flags.<br />

•Notice that the date the borrower signed the final application and the interviewer<br />

date, or essentially the date the final application was completed, is the same date as<br />

that reflected on the initial application.<br />

•This means that the as the initial application was taken, all of the verifications were<br />

obtained and the loan was packaged for underwriting all on the same day. Since this<br />

does not seem plausible, we’ll flag this.


Handwritten & Final Mortgage <strong>Application</strong><br />

<strong>Red</strong> <strong>Flags</strong> Review<br />

• Ask yourself these questions…<br />

• Does the application LOOK legitimate<br />

• Does the information make sense is the borrower profile<br />

reasonable<br />

• Is the information on the initial and final applications<br />

consistent<br />

32<br />

•While it’s impossible to cover every potential red flag, the key concept to take away from this<br />

session is to really look at the information provided and ascertain whether or not it makes<br />

sense and is reasonable.<br />

•When you start to review a file take some time to look at the physical attributes, such as the<br />

consistency of the handwriting and the dates. Does it look like information was added to the<br />

application after it was initially completed and do the dates make sense<br />

•Fraudsters are becoming more sophisticated and it may be difficult to discern fraud from the<br />

documentation provided to you. Therefore, even if the file looks legitimate, ask yourself<br />

whether or not the information provided and verified on the applications makes sense and is<br />

reasonable based on the borrower’s profile.<br />

•And compare the information on the initial application to the final application to identify any<br />

material differences that may need to be resolved prior to closing.


Handwritten & Final Mortgage <strong>Application</strong><br />

<strong>Red</strong> <strong>Flags</strong> Review<br />

33<br />

• Sarge racked up many red flags while reviewing the loan applications.<br />

• It appears that there is more than one person’s handwriting on the handwritten <strong>1003</strong> and<br />

• Gail’s SSN was ‘squeezed in’.<br />

• We also noticed that the assets ended in whole numbers on the final <strong>1003</strong>, meaning the<br />

verified assets ended in whole numbers. This is very uncommon.<br />

• Gail’s employment history doesn’t appear to make sense. Neither of the prior positions<br />

are related to her current position.<br />

• Her income does not seem commensurate with her positions.<br />

• Her savings seem low given the substantial amount of income that Gail earned over the<br />

past several years.


Common <strong>Red</strong> <strong>Flags</strong> & Fraud Schemes<br />

Fannie Mae’s Fraud Schemes and their<br />

Characteristics<br />

https://www.efanniemae.com/utility/legal/pdf/fraudschchar.pdf<br />

PMI’s<br />

PMI’s<br />

Fraud<br />

Closing<br />

Schemes<br />

<strong>Red</strong> <strong>Flags</strong><br />

<strong>Red</strong> <strong>Flags</strong><br />

Checklist<br />

Closing <strong>Red</strong> <strong>Flags</strong> Checklist<br />

Fraud Schemes <strong>Red</strong> <strong>Flags</strong><br />

PMI’s Pre-Closing <strong>Red</strong> <strong>Flags</strong> Checklist<br />

Fraud Schemes Definitions<br />

Pre-Closing <strong>Red</strong> <strong>Flags</strong> Checklist<br />

https://www.efanniemae.com/utility/legal/pdf/fraudschc<br />

Fannie Mae’s har.pdf Common <strong>Red</strong> <strong>Flags</strong><br />

https://www.efanniemae.com/utility/legal/pdf/commonredflags.pd<br />

f<br />

0<br />

•We suggest that you utilize these job aids in your own red flag detection efforts.<br />

•Fannie Mae has a list of Common <strong>Red</strong> <strong>Flags</strong>, which includes the credit report.<br />

•PMI has several checklists dealing with red flags including [CLICK]<br />

•The Pre-Closing <strong>Red</strong> <strong>Flags</strong> Checklist which includes all loan documentation obtained prior to submission of the<br />

loan to underwriter, and the<br />

•Closing <strong>Red</strong> <strong>Flags</strong> Checklist which includes closing-related documentation obtained after loan approval and at<br />

closing.<br />

•[CLICK] The last three resources on this page deal with defining Fraud Schemes and the characteristics associated with red<br />

flags you can identify on the <strong>1003</strong>. Once you identify the red flags you can match them against the potential fraud schemes.<br />

•Let’s look at these schemes in more detail.


Straw Buyers Fraud Scheme<br />

• Straw Buyers<br />

• Straw buyers are loan applicants used by fraud perpetrators to obtain<br />

mortgages, and are used to disguise the true buyer or the true nature<br />

of the transaction.<br />

• Characteristics<br />

• Income, savings and/or credit patterns inconsistent with applicant’s<br />

overall profile<br />

• Inconsistent signatures throughout the file<br />

35<br />

•I’ll not go into detail on all of the characteristics associated with each scheme since you can<br />

obtain this information by reviewing both Fannie Mae and PMI’s checklists; however, I would<br />

like to provide a brief overview of the definition of each of these schemes and the main<br />

characteristics associated with the loan application.<br />

•We’ll start with straw buyers.<br />

•A fraudster disguises the true identity of the buyer and uses ‘fake’ borrower information to<br />

obtain the loan.<br />

•Some of the characteristics associated with straw buyers are:<br />

•The income, savings and/or the credit patterns are inconsistent with the buyer’s<br />

overall profile<br />

•There may be inconsistent signatures throughout the file.<br />

•We noted both of these red flags in our review of Gail’s loan applications; therefore, we<br />

should be on the lookout for straw buyer characteristics in our review of other loan<br />

documentation in this file.


Identity Theft Fraud Scheme<br />

• Identity Theft/Identity Fraud<br />

• Identity fraud involves the use of another person’s social security<br />

number (SSN), or use of a fraudulent SSN. Identity theft involves theft<br />

of another individual’s identity.<br />

• Characteristics<br />

• Misrepresentation of the borrowers income/assets<br />

• Employment and/or addresses don’t match the credit report<br />

36<br />

•Next we have identity theft or identity fraud. In a nutshell, the borrower’s identity has been<br />

stolen or they are using another person’s identity for use in the real estate transaction. The<br />

borrower is not who he or she claims to be, or parts of the borrower’s application are based<br />

on the actions, such as employment, assets, etc. of another person; or the fraudster is using<br />

his or her own name, but another person’s social security number.<br />

•Some of the characteristics that you encounter on the loan application are:<br />

•Income and assets are misrepresented<br />

•Employment and or addresses on the credit report do not match the borrower’s<br />

application<br />

•Again, we noted some inconsistencies with employment, income and assets in our file;<br />

therefore, it would be especially important in this case to cross-reference the information on<br />

the mortgage application with other documents in the file.


Resource Information<br />

PMI’s Training Bootcamp site<br />

Webinars and On-Demand<br />

PMI’s Toolkits<br />

1<br />

•This concludes our review of red flags basics.<br />

•A copy of this presentation is attached and is available for download.<br />

•[CLICK] PMI has a site devoted to training resources where you can find the job aids<br />

referenced in this module [CLICK] along with others such as the <strong>Red</strong> <strong>Flags</strong> workbook, which<br />

provides more detailed information.<br />

•[CLICK] Also on the site are links to other training presentations in both webinar and ondemand<br />

format.<br />

•Click on the links in the red arrows on this page to navigate to any of these resources.


Take Module 3: SSN & Credit Report <strong>Red</strong> <strong>Flags</strong><br />

for the <strong>Red</strong> <strong>Flags</strong> Course<br />

To get to the next module…<br />

Click Here<br />

SSN & Credit Report <strong>Red</strong> <strong>Flags</strong><br />

2<br />

•Congratulations, you’ve now completed module II of the <strong>Red</strong> <strong>Flags</strong> Course.<br />

•A window will pop up shortly which will allow you to complete the survey and obtain your certificate of<br />

completion.<br />

•If you’d like to continue to the module III of the <strong>Red</strong> <strong>Flags</strong> Course, the SSN & Credit Report <strong>Red</strong><br />

<strong>Flags</strong> module, click on the link shown here.<br />

•Thank you for attending PMI’s Training Bootcamp. Hope to see you back again soon.

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!