COMPLY NEWS

IMPORTANT Submission Warning regarding RATE SPREADS!!

January 26, 2010

Hope all is going well with your submission preparation.  We just discovered an issue with the Loan Term field (regarding Adjustable Rate Mortgages ARM) that may affect your file.  This issue only affects ARM loans, so if you don't do ARM loans or only do a couple, it should not be hard to verify and/or correct.

The issue has to do with the import functionality and how we are converting the Loan Term for Adjustable or Variable Rate loans.  Somehow the date select condition did not get into the routine, so it is doing the Adjustable Rate processing on all ARM loans regardless if the Application Date is prior to 10/1/2009 or not.  The fix for this issue is pretty simple, but we need to identify which customers this affects as well as how many applications, to give you a strategy to fix.

There is one other scenario that can affect the applications with Application Dates after 10/1/2009 as well.  If we helped you set up your Import Definitions and we put in code to convert the Loan Term, chances are we didn't put a date range in there either.  So that situation will have to be corrected also if you do ARM loans.

This will not be an issue going forward, just for this transitional period.  We apologize for any inconvenience this may cause, but we are hoping the fix will be painless on a case-by-case basis.  You will be contacted by a RATA Support Representative to try and ascertain your exposure and to help you determine the course of action to fix the issue based on your individual situation.

If you need faster service please feel free to call us.  One way to help is to run a few filters in Comply to see if you are affected.  Simply go into your standard Application View, select the Additional Tab and then look at your Amortization Type.  You will want to filter down to Adjustable (2) and that will tell you potentially how many applications are affected.  Then you can sort by Application Date and look at a few with Application Dates before and after 10/1/2009 to make sure the correct Loan Term is showing.  For ARM apps prior to 10/1/2009 the Loan Term should be the full Term.  For ARM apps after 10/1/2009 the Loan Term should be the fixed portion only.

If you don't use one of our conversion Import Definitions or the Virtual Amortization converter in the Import Wizard, then you shouldn't have an issue, but we recommend you check anyway to make sure your programmers have dealt with the situation correctly.

Again, this should not be hard to fix.  The hardest part is identifying the issue.  As mentioned earlier, we will be contacting you but if you would like to deal with this sooner, feel free to call us at 407-831-7282.

Thank you.