Visionet strives to stay ahead of the curve as the rules change and the predatory lending legislative landscape evolves. VisiHCLAS (High Cost Loans Analysis System) assists individuals with staying on top of all of the changes. We make sure to be aware of any upcoming changes through extensive research and through aggregating our sources.
Predatory lending has been described by federal agencies as involving one or more of these elements:
The view from a lender’s perspective is different. A NHEMA study of over 961,000 mortgage loan applications at multiple lenders in 2004 shows that lenders priced their loans based on risk characteristics such as FICO score, lien position (1st or 2nd lien), monthly income, documentation of income, LTV and whether the loan included a prepayment penalty. In other words, the risk characteristics determine how a mortgage is to be structured. HOEPA provides relief as does Section 32 of Regulation Z. However, many other states have gone beyond the basics and enacted their own legislation. The State of Georgia is an interesting case in point. This particular law includes three important general prohibitions, which apply to all home loans, not just high cost loans:
It also puts limits on high cost loans and further restricts the terms of high cost home loans to protect consumers:
Channel/Broker/Area Specific Rules
Corporate Guidelines and Interpretation of Statutory Rules
Base/HOEPA/Section 32 and State Rules
Visionet’s High Cost Loans Analysis System – VisiHCLAS is designed to provide flexibility and speed though exception management based workflow.
VisiHCLAS allows users to specify one or more loan numbers to be setup for review within VisiHCLAS. In response, the system absorbs the loan data and fee information from the Loans Analysis System and sets up any necessary tasks for loan analysis within the system.
High Cost Loans Analysis System provides a view to each user as to the number of loans that they have setup for review and the loans that they have completed the high cost analysis. The users can filter this view through various attributes like, date range, loan number, borrower name, state of the subject property, etc.
This application feature allows authorized users to configure the following rates along with their application dates:
State Limit configuration
This configuration feature allows authorized users to configure the state rules related limits and parameters used in the state rules for high cost loans validations, the application will also associate version numbers to each of these parameters to facilitate association with relevant version of the state rules.
A database table stores state high cost validation rules in the Visionet designed rules format. Each rule has an associated version number and application date.
The users can key-in additional loan parameters and fee information that is not available in the point of sale (POS) and/or loan origination system (LOS) but is required to carry out the high cost validation.
Business Rules execution
This core feature of the application can carry out the high cost loan validation in terms of the following:
Annual Percentage Rate (APR) Calculator
Visionet has integrated the APR Calculator component into the Visionet’s High Cost Loans Analysis System application to facilitate calculation of the APR for a given loan. The calculated value for the APR is used by VisiHCLAS in validating the loans for high cost analysis.
During the course of the loan analysis for high cost validations, the users need to try various combinations of fees and interest rates to find an appropriate set of loan parameters that best serve the statutory limits set by high cost loan federal and state regulations. High Cost Loans Analysis System Application allows the users to save multiple loan scenarios thereby allowing the user to run various scenarios for each loan until they select one of them to be the final disposition that will then appear in the result report.
Loan Origination System (LOS) Interface
Visionet’s High Cost Loans Analysis System Application interfaces with the all major Loan Origination Systems (LOS). VisiHCLAS is also MISMO compliant. The application supports a state of the art .NET architecture. The clients can access the system through web services (automatically – behind the scenes), batch (run all loans through the system) or manually (check one loan at a time).
Loan Origination System (LOS) Update
Once a particular loan has been verified to be complying with the high cost regulations, the loan and fee data for the selected loan scenario can be updated in the Loan Origination System (LOS) and the system will not allow any further changes to that loan’s data within High Cost Loans Analysis System Application. If the users need to revalidate that loan, they will have the ability to setup another round of loan analysis within High Cost Loans Analysis System Application.
Administrator / Supervisor View
VisiHCLAS (High Cost Loans Analysis System Application) provides a view to designated supervisor level users to see all the loans that are present in VisiHCLAS. This includes the list of loans for which the loans analysis is in progress and also the loans for which the analysis has already been completed. The users are able to filter this view through various attributes like, state of the subject property, date range, team members carrying out the loan analysis, loan number etc. Some of the key reports are:
Loan High Cost Validation Result
This report will be printed for each loan at the completion of the high cost loan analysis for a given loan. The exact format of the report and filter options is documented in detail in the High Cost Loans Analysis System functional specifications document.
Loan Status Report
This report allows the users to print a report on the loans that are present in High Cost Loans Analysis System and the users to filter the results based on date range, loan analysis status (completed/in-progress), borrower name, etc.
Visionet’s High Cost Loans Analysis System uses an open SQL 2000 database architecture. Customers can choose to leverage any of their existing reporting tools and produce reports pertinent to their business needs. Visionet will constantly add new reports as well or by request.
Working with Visionet has been instrumental in allowing us to innovate and provide better overall customer experience throughout our website. Their thought leadership, broad technical capabilities, and extensive portfolio allows us to engage with them on many different projects.
Director of Ecommerce
Dooney & Bourke
Visionet came in with key domain understanding of our business and in short order helped us craft a reporting structure on time and in budget. We value their expertise and partnership to our company
Mr. Stuart Werner
We had changed our e-commerce platforms several times but still struggled to find the right platform to meet our growing business demands. We needed the new Demandware platform to be implemented before the holiday season, and I’m thrilled that Visionet Systems was able to deliver against a tight deadline.
VP Marketing & e-Commerce Operations
Working with Visionet’s team had been a great experience allowing us to leverage on their wealth of experience. We are now well-enabled to offer exhibitors an enriched ordering experience through quick and easy-to-use functionality and enhanced functions
Mrs. Trish Webb
VP, Application Development
Challenges in meeting the GSE mandate for uniform closing dataset (UCD) delivery
Date: September 20th, 2016 02:00 PM EST