Question
Upon
reviewing and updating our Post-Closing Quality Control Plan, we noticed that
it says we must obtain Residential Mortgage Credit Reports (RMCRs) when
auditing our files. Is this correct or can we use Tri-merge Credit Reports?
Answer
Yes,
you may obtain Tri-merge Credit Reports instead of RMCRs as part of your Post-Closing
Quality Control Program. The following are the requirements per HUD, Freddie
Mac, Fannie Mae and VA.
HUD
A new credit report must be obtained for
each borrower whose loan is included in a Quality Control review; unless the
loan was a streamline refinance or was processed using a FHA approved automated
underwriting system exempted from this requirement. A credit report obtained
for a Quality Control review may be a Residential Mortgage Credit Report, a
three repository merged in-file report or, when appropriate, a business credit
report. [HUD Manual 4060.1 Mortgage Approval Handbook, Section 7-6, E1. (08-06)]
Freddie Mac
For Loan Prospector Mortgages, the Seller
is not required to obtain a new credit report.
For one out of every ten Non-Loan Prospector Mortgages selected for post
closing quality control reviews, the Seller must obtain either a new
Residential Mortgage Credit Report or a three-repository merged in-file credit
report. For the remaining Non-Loan Prospector Mortgages in the Seller’s post
closing quality control sample, the Seller must obtain new in-file credit
reports containing information from one or more of the national repositories. [Freddie
Mac Single Family Seller/Servicer Guide, Section 48.5, (c) (05/15/12)]
Fannie Mae
For all loans selected via the random
selection process (and for loans selected through the discretionary selection
process, as applicable), the post-closing QC review must include reverification
of the borrower’s credit history. If a borrower’s credit was evaluated by using
a traditional credit report, the lender must reverify the borrower’s credit
history by obtaining a new tri-merge credit report. [Fannie Mae Single Family,
2013 Selling Guide/Part D, Ensuring Quality Control, Section D1-3-02
(07/30/2013)]
VA
Reordering of a new credit from another
credit source. Report may be a RMCR or an in-file report which merges the
records of the three national repositories of credit files, commonly know as a
3-file merge. [VA Lender Handbook,
Chapter 1, 15-1Review of Loans (09/15/2014)]
Bruce
Culp
Director/Quality
Control & Loan Analytics
Lenders
Compliance Group
