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Certification of Loans and Investment Pools
Growing
concerns have been reported that our mortgage industry and securitization
markets are clearly behind the curve regarding certification, which could
negatively impact investment in mortgage-backed securities. The current trend
in business worldwide is greater accountability, due diligence, quality
assurance and certification of both products and services. The International
Organization for Standardization’s ISO 9000 series, new AICPA (American
Institute of Certified Public Accountants) standards, government agencies,
manufacturers, and other professionals are seeking and expecting new ways to
increase the level of confidence for investors, customers and regulatory
agencies. In the financial arena, oversight agencies including FASB and the SEC
have been applying pressure for higher standards of accountability. OFHEO (the
Office of Federal Housing Enterprise Oversight) and Congress are raising
similar issues for the Government Sponsored Enterprises, Fannie Mae, Freddie
Mac and the Federal Home Loan Banks.
As loan servicing operations consolidate, their fiduciary responsibility and
liability for a greater market share of securitizations increase dramatically.
It’s apparent and understandable why investors, borrowers and oversight
agencies will expect ever-stricter quality assurance and accountability.
Dramatic breakthroughs in technology are now providing the means to meet and
exceed many of these expectations both efficiently and cost effectively
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Only an independent third party can issue valid certification in compliance
with recognized certification standards, and certification cannot be issued by
government agencies. Thus, HUD, Fannie Mae, Freddie Mac, the SEC and other
government related organizations cannot assume a certification role but will
expect it from their suppliers.
Mortgage
Analysis Computer Corporation (MACC-TRAC© )
has a tight grasp on the issues, criteria and technology of mortgage servicing
and has been providing branded certification of loan pools to its clients as
part of its outsource service. The firm’s technology is now available for
others to use to implement consistent and reliable certification testing and
reporting.
The MACC-TRAC Vision Pro System© provides the
means to achieve the highest level of data integrity, electronically integrate
all posting activity, recognize and identify all discrepancies and reconcile
information to produce correct results and analytical reports. Once loans are
boarded on to the system, a complete update on any loan or pool of loans can be
generated at any time. This concept is consistent with a new emerging
accounting standard referred to as Continuous Audit.
The MACC-TRAC Vision Pro System© design
permits inclusion of additional data fields that the user may deem appropriate
to expand certification criteria. This is why we invite your participation.
MACC-TRAC©
branded certification drills down with D3, Dynamic Data Discrepancy™, to assure
that servicing system data are correct and reflect exactly the terms of loan
documents. Every loan is then recomputed using the corrected data and the
actual pay history, which has been electronically integrated. The system
reconciles any differences that may exist in the allocation of principal,
interest, and curtailments. The cascade effect of errors caused by incorrect
data, incorrect payment allocation and erroneous computations is a source of
significant risk for loan servicing enterprises and can have substantial
financial consequences for both investors and borrowers.
A complete and thorough certification program must also include due diligence
examination of documentation, compliance with state and federal rules and
regulations, fraud review, and other standards.
A loan pool could, for example, be certified under MACC’s
branded data and computational standards but not be certified with respect to
missing compliance documents or other audit criteria.
Since 1989, Mortgage Analysis Computer Corporation (MACC-TRAC©)
has been serving investment bankers, financial institutions, federal agencies,
accounting firms and others who have been ahead of the curve in seeking
MACC-TRAC© loan servicing certification.
Consequently, criteria and technology solutions and systems developed by
MACC-TRAC© have positioned the firm to lead
the industry in establishing standards for certification of loans, loan
investment pools and loan servicing operations.
The following web sites provide resources regarding the trend for
certification.
Author: Robert Wesley “Bob” Brown
1(800) 444-7071
President & CEO - MACC-TRAC
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| email: bobbrown@macc-trac.com
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