All policy changes and updates are referenced below to the appropriate section of the CLG. These policy changes are effective 07/21/2022 unless otherwise noted.
To review the program guidelines changes made July 7, 2022, or earlier, please follow this link to the archived Correspondent Lending Guides.
This announcement, and previous announcements, are also available on the Announcements page of our website.
These updates apply to everyone using the Chenoa Fund™ program—correspondents and TPO.
Language regarding bona fide discount points, as well as language regarding converting seller credits to sell-paid fees, has been simplified. Several sections have had their language simplified to the following, while other sections have had their language changed to otherwise reflect this change:
Discount Points: Regarding discount points, CBCMA follows CFBP and relevant Agency guidelines for TRID, including the QM 3% Points and Fees test.
Seller Credits: CBCMA takes the position that seller credits may be used to pay for origination points or discount points. Please see the addendum to the note (follow this link and select “Originator Resources”; the addendum follows the Buckley-Sandler memo in the same document) for further explanation of CBCMA’s position.
Keep in mind that converting seller credits to seller-paid fees must be done prior to or at closing. Seller credits used to offset points and fees must be disclosed on the initial and final CD; they cannot be corrected after closing.
The above changes affect the following sections:
5.22.1 (Fees to CBCMA)
5.22.2 (Seller Credits and the Buckley-Sandler Memo)
7.5 (QM Points and Fees Calculations)
7.6 (Additional Guidance from CFPB on Appropriate Interest Rate for Excluding Discount Points Under Final ATR Rule)
7.7 (Seller and Lender Credits and QM Points and Fees)
7.8 (Important Notice Regarding CBC Mortgage Agency Investor Delivery Fee and Clarification of Rate Sheets) 7.8.1 (Seller Credits and the Buckley-Sandler Memo)