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CBCMA’s requirements for credit refresh or a UDM 10 days prior to note date

We’ve recently seen an increase in confusion regarding CBCMA’s requirements for credit refresh or a UDM 10 days prior to note date. Some lenders are using credit monitoring services that do not conform to Fannie Mae’s LQI criteria. The purpose of the credit-refresh is to ensure the loan approval (AUS) remains accurate and the borrower qualifies for the loan at time of closing.

Some lenders provide credit monitoring from companies the borrower has enrolled in. These usually do not suffice because they generally pull from one bureau and are primarily designed to provide borrowers with information regarding changes in their credit. They are not reflective of the sources used in the original credit approval. A UDM report that does qualify includes all three bureaus, shows new inquiries, any new BK, judgements, liens, collections, late payments and payment and balance increases on existing trade lines.

After a review of the Fannie Mae Selling Guide and, HUD’s 4000.1, for when a borrower must be requalified following any new or increased debt identified prior to loan closing:

All Programs: All borrowers must have at least one credit score. CBCMA will require a tri-merged/three-bureau, soft-pull credit refresh, dated within ten (10) days of the note date. An Undisclosed Debt Monitoring (UDM) product may be used in lieu of a soft-pull credit report as long as the UDM covers all 3 bureaus and is current within 10 days of note date. When a credit refresh or UDM discloses discrepancies between the original credit report payments and balances used in the original qualification of the borrower as reflected on the AUS, including the presence of additional debts or increased debt load, a resubmission of the AUS with updated liabilities is required according to the following tolerance thresholds:

FHA: The Mortgagee must re-score a Mortgage when any data element of the Mortgage changes and/or new Borrower information becomes available.

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FHA: The Mortgagee must re-score a Mortgage when any data element of the Mortgage changes and/or new Borrower information becomes available.

Thank you,

CBC Mortgage Agency