NAMP CMLP cheat sheet
NAMP CMLP · Keep the key ideas within reach.
Mortgage Loan Origination Practice and Ethics
SAFE Act: MLOs must be licensed or registered through NMLS, complete 20 hours of pre-licensure education, pass the SAFE test, submit fingerprints, and complete 8 hours of annual continuing education.
RESPA Section 8 prohibits any fee, kickback, or thing of value for referral of settlement service business; bona fide compensation for goods or services actually performed is permitted if disclosed.
Regulation Z loan originator compensation rule: pay cannot be based on loan terms such as rate, APR, or fees, except the amount of credit extended; dual compensation from borrower and lender is prohibited.
Advertising: the MLO NMLS unique identifier and licensed entity name must appear on business cards, websites, and ads; triggering terms such as a rate or payment require additional disclosures.
ECOA/Reg B prohibits discrimination based on race, color, religion, national origin, sex, marital status, age, or receipt of public assistance; the Fair Housing Act adds familial status and disability.
UDAAP: unfair, deceptive, or abusive acts or practices are prohibited; examples include misrepresenting loan terms, hidden fees, and steering qualified borrowers to higher-cost loans.
Record retention: Regulation B requires 25 months (12 months for business credit); RESPA requires 3 years; TILA requires 2 years after consummation.
Privacy: GLBA requires delivery of a privacy notice, opt-out rights before sharing nonpublic personal information with nonaffiliates, and safeguards for customer data.
Federal Lending Regulations and Compliance
TRID Loan Estimate: must be delivered or placed in the mail within 3 business days after application; a revised LE is required if the APR changes by more than 0.125% (0.25% for irregular transactions).
Closing Disclosure: the borrower must receive it at least 3 business days before consummation; the period cannot be waived, and a revised CD restarts the period if the APR increases by more than 0.125%.
Tolerances: zero tolerance applies to creditor and affiliate fees and services required by the creditor where the borrower cannot shop; 10% cumulative applies to recording fees and other listed items; unlimited applies to borrower-shoppable services and prepaid interest.
ECOA adverse action: the creditor must notify the applicant within 30 days of receiving a complete application; the notice must state the action taken and the reasons or the right to request reasons.
Right of rescission: 3 business days for a refinance or HELOC secured by the principal dwelling; it does not apply to purchase loans or business-purpose loans; the period begins at consummation or disclosure delivery, whichever is later.
HPML: a first-lien APR exceeding the average prime offer rate by 1.5 percentage points (3.5 for subordinate liens); requires an escrow account and appraisal and restricts prepayment penalties.
Flood Disaster Protection Act: mandatory flood insurance for improved property in a Special Flood Hazard Area; minimum coverage is the lesser of the outstanding principal, insurable value, or NFIP maximum.
ATR/QM: general QM requires no negative amortization, no balloon payment, a term of 30 years or less, a points-and-fees cap (3% for loans of $100,000 or more), and consideration of eight underwriting factors.
Loan Products, Programs, and Pricing
2025 conforming loan limit for a one-unit property is $806,500 in baseline areas; the high-cost ceiling is $1,209,750; loans above the applicable limit are non-conforming (jumbo).
FHA purchase: maximum LTV is 96.5% for a 30-year fixed; upfront MIP is 1.75% of the base loan amount and may be financed; annual MIP is 0.55% when LTV exceeds 95% and 0.50% when LTV is 95% or less.
VA: eligible veterans can finance 100% of the purchase price; the funding fee is 2.15% for first use with 0% down and 3.3% for subsequent use; the fee can be financed and is waived for certain disabled veterans.
USDA Rural Development: 100% financing for eligible rural households within income limits; upfront guarantee fee is 1.0% and the annual fee is 0.35% of the loan balance.
ARM structure: an initial fixed-rate period followed by periodic adjustments; common caps are 2% initial, 2% periodic, and 6% lifetime; margin plus index (such as SOFR) sets the adjusted rate.
Discount points are prepaid interest: one point equals 1% of the loan amount and generally lowers the note rate by about 0.25%; origination fees compensate the lender for originating the loan.
Seller concessions: conventional limits are 3% for LTV above 90%, 6% for LTV from 75.01% to 90%, and 9% for LTV at or below 75% on primary residences; FHA allows up to 6%.
Credit, Income, and Underwriting Analysis
DTI = total monthly obligations (PITI plus all debts) divided by gross monthly income; ATR/QM evaluates DTI along with income, assets, credit, and reserves.
Credit score: a tri-merge report provides three scores; underwriting uses the middle score of the primary borrower, and the lower middle score drives pricing and eligibility.
Self-employed income: generally 2 years of tax returns averaged, plus a year-to-date profit and loss statement; declining income may require use of the lower year.
Derogatory credit waiting periods: Chapter 7 bankruptcy 2 years from discharge; Chapter 13 4 years from discharge or 2 years from dismissal; foreclosure 7 years; short sale or deed-in-lieu 4 years.
Reserves are liquid assets remaining after closing, measured in months of PITI; requirements increase with multiple financed properties and higher LTV.
AUS findings: Desktop Underwriter and Loan Prospector issue Approve/Eligible or Accept recommendations; manual underwriting requires documented compensating factors.
Student loans: if deferred or income-driven, qualify using 1% of the outstanding balance or the actual documented payment; use the fully amortizing payment when in repayment.
Closing, Settlement, and Loan Documentation
Closing Disclosure must be received by the borrower at least 3 business days before consummation and must reflect final loan terms, projected payments, closing costs, and cash to close.
Promissory note: a written promise to repay the loan; it states the principal, interest rate, payment schedule, late charges, and prepayment terms.
Security instrument: a mortgage (judicial states) or deed of trust (trustee states) gives the lender the right to foreclose if the borrower defaults; riders add terms for ARM, condo, or PUD loans.
Title insurance: the lender's policy protects the lender's interest and is required; an owner's policy protects the buyer and is optional but customary in many areas.
Wire fraud prevention: confirm wiring instructions by calling a known, independently verified phone number; never rely on email instructions; use dual verification.
Prorations: taxes, interest, and rents are allocated between buyer and seller as of the closing date; escrow holds funds for taxes and insurance.
Recording: after closing, the security instrument and deed are recorded with the county; MERS may be named as mortgagee of record to track assignments.