New federal mandates are coming in at an unprecedented pace. Since January 1, 2011 alone the introduction of new loan officer comp rules and the NMLS reporting requirement have caused quite a stir in the mortgage technology industry. Ensuring you are compliant with all these new rules and regulations is imperative.
One core challenge to meeting these requirements is staying current on your various technology platforms. An unfortunate byproduct of these new rules is less new features are being released by the major loan origination vendors, namely Calyx Software, DMD and Ellie Mae. Another unfortunate byproduct is higher prices by these vendors to maintain your software subscriptions, without many of the new features you might normally expect.
We can thank the feds for these higher prices and lack of innovation. The development and maintenance costs are increasing exponentially for these software vendors, as is the speed in which the releases are being produced. This translates directly into higher prices.
Also, as a mortgage broker or lender, you no longer have the luxury of skipping releases to keep your costs down.
Letting your software subscription agreement expire even for a calendar quarter means you could be instantly out of compliance for all new originations (think the ever evolving GFE).
So how do you ensure you are staying in compliance? Simple, keep your software subscription current with your LOS vendor and, equally important, make sure your organization is applying all new version releases and services packs. This sounds like basic housekeeping for a software installation, and it is, but with multiple releases produced just in the first four months of 2011 this can easily be overlooked.
Calyx Software has released three services packs this year already, and DMD has produced two. Each release requires the involvement of your firm’s upper management team, as well as the tech team or outside support, to get it scheduled and installed. This is more time and expense as compared to years past, but it’s essential to keeping your systems up to date and compliant.
The lack of new features from the LOS vendors can be expected for at least the coming 12-18 months as new compliance requirements continue to hit. With the last of the major compliance initiatives likely over in the second half of 2011, it will take the software vendors 2-3 additional quarters to begin to develop and test any truly new features.
If you have needs outside of the core origination feature set, and you’re waiting on your LOS vendor to release them, be prepared to wait or start looking elsewhere for a complimentary solution. Sales and marketing automation, borrower communications solutions and general pipeline management solutions are all areas that will likely continue to fall outside of the LOS vendors’ “sweet spots” for quite some time to come.
It’s also important to note that numerous states are starting to require that your technology infrastructure also be compliant to new tougher security restrictions. Specifically, protecting borrower data continues to be at the forefront for many new state requirements.
Keeping your critical loan and borrower data inside your office, or worse, directly on a laptop, is quite often out of these compliance guidelines.
Most states accept that data stored within a SAS70 Type II data center is compliant to these new rules, as this is the FDIC mandate for all its chartered institutions. Getting your data to one of these facilities is easier than you might think, but it takes a bit of research and planning. First, you have to select the right vendor. Next, it’s imperative that this vendor provide its SAS70 report to you and require that they update it annually. Last, coordinating the move with your IT staff and end users for a time that is least disruptive to your production cycle is critical to success.
Maintaining compliant systems is difficult, to say the least, in today’s hostile environment. The easiest place to start is keeping your software current, and your data in a very safe facility.
Josh Bopp is the president of focusIT, Inc., the largest mortgage technology hosting company in the US. To learn more about focusIT visit www.focusitinc.com. Specific questions about this article can be directed to Josh Bopp at email@example.com.