First mortgage FHA 203(k) Program PROGRAM TRAINING

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Presentation transcript:

First mortgage FHA 203(k) Program PROGRAM TRAINING Desktop Underwriter is a registered trademark of Fannie Mae. Loan Prospector is a registered trademark of Freddie Mac. This presentation is a summary and is not complete. This information is for mortgage professionals only and should not be distributed to or used by consumers or other third-parties. Information is accurate as of the date shown below and is subject to change without notice. 05/5/2015

Agenda Introduction to FHA 203(k) Featured Products – Standard & Streamline 203(k) Available FMC 203(k) Program Program Underwriting Guidelines Draw Process FHA 203(k) Resources Tips & Reminders Certification & Flow Process How to complete the 203(k) Maximum Worksheet HUD-92700

Why 203(k)? This is HUD’s primary program for the repair and rehabilitation of single family properties. The Federal Housing Administration 203(k) Program allows borrowers to purchase or refinance their home and include the costs to repair or rehabilitate it in the same loan. When buying a house that needs modernization, homebuyers usually have to follow a complicated and costly process. The interim acquisition and improvement loans often have relatively high interest rates, short repayment terms and a balloon payment. BENEFITS OF THE PROGRAM: The FHA 203(k) can help borrowers: Offer a solution that can help borrowers obtain financing that covers both the acquisition and rehabilitation of the property Help borrowers save time and money The FHA 203(k) can help you: Expand your market reach Increase your loan origination volume Help borrowers find affordable financing and realize the dream of homeownership 3

FMC’s Available Fha 203(k) program First mortgage FMC’s Available Fha 203(k) program

Featured Products Allows borrowers to finance an additional $35,000 into their mortgage to make improvements Minimum $5,000 rehabilitation amount Available for purchase and rate and term refinance transactions Allowed on limited improvement types Can be 100% cosmetic improvements Can NOT be used for structural improvements or repairs Streamlined 203(k) – the improvements and the disbursement process are Streamlined HUD Cost Consultant may be required STREAMLINE FHA 203(k) Streamlined 203(k) intended for uncomplicated rehab where plans, consultants, engineers and/or architects are not required

Streamlined FHA 203(k) Eligible Improvements Streamlined 203(k) intended for uncomplicated rehab where plans, consultants, engineers and/or architects are not required

Targeted Market? Borrower’s purchasing a home in need of repairs May be REO’s, foreclosures and short sales REO’s are a significant portion of the purchase market Out-dated kitchens, bathrooms, etc. Borrower’s refinancing an existing home and making improvements Improve instead of move 7

Available FMC Programs Investor: FMC – Program …07 Minimum Fico: 580 Minimum for Conforming L/A 620 Minimum for Jumbo L/A Disbursement Turn-times: 10 days after closing Pricing: Use regular 07 pricing 203(k) price hit Fico score hits Program ….07 Streamlined 203(k) intended for uncomplicated rehab where plans, consultants, engineers and/or architects are not required 8

203(k) program guidelines UW guidelines First mortgage 203(k) program guidelines UW guidelines

Base Loan Amount The Base Loan Amount is calculated as follows… OR PURCHASE (See Section C of the HUD-92700 Worksheet) Up to 96.50% of the LESSER OF: Purchase Price A1 (or As Is Value A2) PLUS Total Rehabilitation Costs B14 OR 110% of the After-Improved Value A4 REFINANCE (See Section D of the HUD-92700 Worksheet) The LESSER OF: Sum of the Existing Debt A1 PLUS Total Rehabilitation Costs B14 PLUS Borrower Paid Closing Costs and Prepaids A5 LESS Discount on Repair Costs B12 97.75% of the Lesser Of the Sum of the As-Is Value PLUS Rehabilitation Costs OR 110% of the After-Improved Value A4 Construction of the property must have been completed for > 1 year

Program Eligibility Guidelines Topic Description Geographic Areas CA, NV, AZ, WA, OR Eligible Programs 30-year fixed-rate mortgages 1-year adjustable-rate mortgages (Not available with Jumbo loans) Optional temporary 2/1 buydown Loan Purpose Purchase – Up to 96.50% LTV Purchase & Rehabilitate existing structure completed for > 1yr Refinance – Up to 97.75% LTV Rehabilitate existing structure completed for > 1 yr Rehabilitate a structure completed > 1yr and refinance outstanding balance Occupancy Owner-occupied, primary residence Rehabilitation Amounts Minimum - $5,000 Streamlined FHA 203(k) $35,000 maximum Construction of the property must have been completed for > 1 year

Program Eligibility Cont’d… Topic Description Eligible Borrowers US Citizens Permanent & Non-Resident aliens Non Occupant Co-borrowers – NOT ALLOWED Co-Signers – NOT ALLOWED Eligible Properties Attached and detached single family residences and PUDs 2-4 unit properties Condos in FHA approved projects (with restrictions) REO-owned properties Ineligible Properties Manufactured Homes Homes that have never been completed Homes that have been completely demolished including foundation Log Homes Condotels Cooperatives Conversions from SFR to units (2-4 units) FMC Overlay Cash-Out Not Allowed. Loan must not exceed actual cost of construction, the purchase price or refinance of an existing lien, and reasonable closing costs. Any loan proceeds not advanced must be applied to principal.

UW Guidelines Topic Description Underwriting Method DU Approved/Eligible OR Loan Scorecard Required Minimum Fico 580 for Conforming Loan Amounts 620 for Jumbo Loan Amounts FMC Overlays Credit scores between 580 and 620, regardless of DU findings also require: No derogatory credit within prior 12 months VOR required for prior 12 month history substantiated with 12 months cancelled checks and/or bank statements (borrower’s living with relatives who cannot verify rental history must have demonstrated savings ability and gifts are not allowed) Homebuyer education required when qualifying score is < 620 Non Traditional Credit – ZERO score borrowers Not Allowed Qualifying Ratios 31% / 43% May be exceeded with AUS approvals Interest party contributions Allowed up to 6% Down Payment Purchases – 3.5% minimum required Checking, savings or other depository accounts 401(k) Gift from relative, fiancé/fiancée or domestic partner Cash-on-hand

OTHER INFORMATION (CONTINGENCY RESERVE, SELF-HELP, COST CONSULTANT) First mortgage OTHER INFORMATION (CONTINGENCY RESERVE, SELF-HELP, COST CONSULTANT)

Borrower Self-Help? Work must be completed by a Licensed Contractor only!!! Borrower must be a Licensed Contractor if they want to do the work themselves Borrower related contractors are not allowed per HUD guidelines – See Borrower’s Identity of Interest Form and ML 2000-25 15

Contractor Requirements One licensed General Contractor is allowed; multiple general contractors not allowed at FMC Contractor must be licensed if required by State and must provide evidence of Liability Insurance coverage valid through period of rehabilitation completion date. Contractor must be licensed a minimum of 6 months beyond the completion date. Exceptions allowed down to 3 months on a case-by-case basis with prior approval Minimum $250k insurance required Exceptions allowed on a case-by-case basis with prior approval All FHA 203(k) loans require that a borrower-selected contractor sign the "Homeowner/Contractor Agreement" before closing. 16

Bids/Work Write-Ups, Cost Estimates The bid provided by the contractor must be ACTUAL bids for work; not cost estimates The work write-up within the bid must clearly define the scope of work being performed The work write-up must provide the breakdown between Labor and Material Any Health and Safety concerns must be accounted for in the bid (if applicable) There are cost estimates from all contractors and vendors providing services/work There is a signed corresponding Homeowner/Contractor Agreement from each contractor or vendor providing services/work If there are changes, the appropriate change order forms are in the file $1,500 Pool and In Built Spa repair cap – above $1,500 (even for Health and Safety) may not be financed into the 203(k) 17

Cost Consultant https://entp.hud.gov/idapp/html/f17cnsltdata.cfm Not Required on Streamline 203(k) May be required at the discretion of the Special Products Division Consultant Fee MUST be disclosed upfront in the event it is required Cannot be financed into the loan If the UW feels the cost estimates are not realistic, they may ask for a 2nd opinion from another Contractor. This will be part of UW review. A HUD Approved Cost Consultant (if required) is selected to: Visit the site Prepare work write-up that specifies a description and cost of each work item Review the architectural exhibits for compliance with HUD’s Minimum Property Standards Work with the Contractor to ensure work is eligible, cost is reasonable, whether any permits are required, any recommendation Inspect any of the property’s health and safety items noted on the drawing Cost Consultants can be found on HUD’s website: https://entp.hud.gov/idapp/html/f17cnsltdata.cfm 18

Contingency Reserve Used to cover health, safety and unplanned issues that arise during construction Required on properties older than 30 years and/or over $7,500 in rehabilitation costs FMC requires it on all FHA 203(k) loans A minimum of 10% of the cost of rehabilitation If not used (after all construction is complete) the remaining amount will be: Applied to principal only Pad required to cover unplanned/unexpected expenses. Borrower may add if not sufficient. Improvements not affecting health & safety or necessity item must not come from contingency fund but can be paid by borrower.

FHA 203(k) Streamline Misc. All health and safety issues must be repair within the initial draw & lead based paint prior to borrower occupancy Requires the borrower not be displaced by the repairs for more than 30 days after repairs begin (See ML 2005-50) Utilities MUST BE ON for a Streamline 203k; if not, must be done as a Standard 203k loan Does not allow for structural changes (See ML 2005-50) Allows for only two releases. The 1st release at closing should not exceed 50% of the cost of materials (no labor, permits or taxes) Pad required to cover unplanned/unexpected expenses. Borrower may add if not sufficient. Improvements not affecting health & safety or necessity item must not come from contingency fund but can be paid by borrower.

disbursement / draw process First mortgage disbursement / draw process

DISBURSEMENT/DRAW PROCESS Streamline FHA 203(k) Disbursement Turn times: Approximately 10 days after close After the loan is closed/setup: 50% of the rehabilitation funds are disbursed (less 10% holdback) For borrower’s working with a contractor, a W-9 must be provided to establish the contractor as approved A two-party check is made payable to the borrower and the contractor The check will be sent to the borrower Included with the disbursement is an instruction letter that explains how the final disbursement works The balance is disbursed upon completion of ALL work If the cost of the renovation is over $15,000, an inspection by an FMC inspector (the original appraiser if in rural area) is required. In some cases, no inspection required if < $15,000. Two disbursements are made One approximately - 10 days after close Second and final disbursement once ALL work has been completed Line B-1 of worksheet – clarify on HUD-1 so its not re-disbursed

PRICING / FEES (pricing, closing costs) First mortgage PRICING / FEES (pricing, closing costs)

Pricing & Closing Costs Topic Description Origination Fee Max 1% (Borrower Paid ONLY) PLUS Supplemental Origination Fee – see below Must be disclosed on GFE Supplemental Origination Fee Fee allowed by HUD for the Lender who handles the draws, inspections, title update, file close-out, etc. to keep. Calculated at 1.5% of the portion of the mortgage allocated to rehabilitation, or $350, whichever is greater. Collected in addition to the 1% origination fee. Closing Costs Customary and reasonable costs allowed. If paid by borrower, except for discount points, these fees may also be used to meet the borrower’s minimum investment requirement. Borrowers may not pay a tax service fee Discount Points May be financed on the rehabilitation portion only and may not exceed the amount of discount on the non-rehabilitation portion On purchase transactions, discount points above the rehabilitation portion may be charged but not financed

Miscellaneous (FORMS, tips & REMINDERS, tools, fmc support) First mortgage Miscellaneous (FORMS, tips & REMINDERS, tools, fmc support)

*** FHA 203(k) Streamlines - Maximum $35,000 in Repairs)*** FHA 203(k) Checklist ____ Streamline 203(k) Maximum Mortgage Worksheet HUD-92700 (In FB) _____ Contractors Estimate Bid, Signed & Dated by Borrower & Contractor _____ Contractor’s Valid License _____ Valid Liability Insurance _____ W9 – Print signers name on form – Executed by the GENERAL CONTRACTOR only _____ Rehabilitation Loan Agreement, Fully executed _____ Borrower’s Acknowledgment – Borrower/LO to countersign to avoid condition _____ Borrowers Identity of Interest Certification _____ Homeowners/Contractors Agreement – Borrower/Contractor _____ Termite Report & Septic Inspection, if noted on Purchase Agreement _____ Rehab Escrow Account & Fees Acknowledgement _____ Notice to Borrower regarding your Rehab Loan _____ Borrower’s Acknowledgment of Draw Process *** FHA 203(k) Streamlines - Maximum $35,000 in Repairs)***

TIPS - Streamlined FHA 203(k) Tips for handling the initial draw on Streamline 203(k) All disbursements must be reflected on the HUD-1. Mortgage payments cannot be included in the Streamlined 203(k) rehabilitation amount. Always include one inspection in the rehabilitation cost— Typically in the amount of $150 per inspection. Always include the fee for a title update in the rehabilitation cost Typically in the amount of $100. Any remaining funds after the completion of all repair items will be applied in the form of a principal reduction. “Cash back” to the borrower is not allowed. Any unused portion of the Contingency Reserve will be applied as a principal reduction at the end of the rehabilitation process. Watch for incorrect maximum loan amount calculations. Carefully review the appropriate calculations for “as-is” vs. “as-completed” valuations. Ensure all calculations on the Maximum Mortgage Worksheet are correct. Excessive or inappropriate fees may not be added in or reflected in the calculations, instead, note them on the Final HUD-1. Carefully review each document to make sure the appropriate signatures are obtained, CHUMs IDs are noted, and each space requiring information is accurately completed. FHA Case Numbers must be included on all required forms, and the case numbers must be consistent. A typing error or other mix-up in case numbers may result in an unacceptable form. Title updates should be ordered only after completion of repairs has been confirmed. Line B-1 of worksheet – clarify on HUD-1 so its not re-disbursed 27

Tips and Reminders (1)… Make sure all impacted parties understand the draw process – Consultation Call prior to docs When the first and all subsequent draws are made How many draws are allowed – maximum two (2) for Streamline 203(k) Title must be clear before final payment is made FMC does one Title update - $100 cost; Any mechanics lien must be cleared Title Reports – With regard to any notice that the property is substandard on the prelim, processing needs to submit documentation such as contractor’s bid and/or work write up to the title company so title can clear the substandard note and issue a clear title. Notify Title and Escrow UP-FRONT of the 203(k) Transaction Choose a Title Company that will provide a 122 Endorsement. Eg., Chicago Title ServiceLink First American Title Insurance Holdback funds are not released until ALL work is completed Construction must begin within 30 days on FHA 203(k) Streamlined loans. (Weather related and/or other delays are not normally allowed). Licensed Contractor – Work must be done by a licensed contractor. Borrower can do his/her own work only if a licensed contractor themselves. 28

Tips and Reminders (2)… Contractors Itemized Estimates – Make sure there is one in the file. They must show material and labor separately and be legible and total up correctly. FHA 203(k) Forms – Must be in the loan file and must be completed; do not submit signed blank forms. FHA 203(k) Worksheet – Must be in the loan file and must be completed and accurate; incomplete worksheets are not acceptable. Discount Points - Total AMOUNT of discount points on Rehab portion (which can be financed as part of the total rehab) cannot exceed total AMOUNT of discount points on the non-rehab portion. Supplemental Origination Fee – All 203(k) loans must include this fee – this is NOT OPTIONAL! Charged for handling rehabilitation process ($350 or 1.5% whichever is greater). Cost Consultant – When using a consultant, include their invoice to determine if it needs to be included in the rehab amount or not. Rehab Amount (Line B14 of 203(k) Worksheet) – Must be included in First Base so it’s reflected on the DOT and funds to close are as accurate as can be. Details of Transaction (In DU/DO) – must include the Rehab amount. Utilities – Appraiser needs to mention that utilities are on; otherwise loan cannot be done as a Streamline 203k.

Tips and Reminders (3)… Termite Report – If termite report shows section 1 items need to be completed, they need to be itemized on the work write-up. Line B-14 of 203(k) Worksheet – Make sure the amount reflected here includes the total rehab loan amount. Must include contractors estimates and all the rehab costs so if you’re doing a Streamline 203(k), the total amount here cannot exceed $35,000; if it does, loan cannot be done as a Streamline 203(k). Contractor’s License – Must be current and valid; cannot be expired. Must be current through the end of construction. 6 mos minimum for Streamline. Use the link on the Resource page to check. Pool – Can finance up to $1,500 to repair an existing Pool. Pool must be filled prior to closing; cannot be empty. Health/Safety Items – The appraiser can list the health/safety items that require repair, and they should all be on the contractors estimate. The appraiser should also list any health/safety items NOT addressed in the contractor’s estimate, then the cost estimate would have to be revised to include any additional health/safety items noted by the appraiser. Process Flow – Follow the Process Flow in place when doing 203(k) loans. Try to always get a Contractor’s Estimates first BEFORE the appraisal is ordered. This will eliminate the Appraiser asking for health/safety issues to be cleared before closing and the constant back and forth causing unnecessary delays. Related Contractors – NOT ALLOWED at FMC. See Borrower Identity of Interest Form for HUD rule. 30

Tips and Reminders (4)… FHA Connection (Tips on Inputting FHA 203(k) on FHA Connection): Under HUD Consultant ID, input “203ks” Initial Disclosures (Tips on where to put B14 on Initial GFE and Est. HUD-1 for FHA 203(k): Block 1 of GFE: Input your regular Fees PLUS Supplemental Origination Fee Block 6 of GFE: Input the balance of line B14 from the HUD-92700 Section 1300 of HUD-1: Total from B14 Section 100 of HUD-1: B14 will be in “Total Settlement Charges” 31

FHA 203(k) Resources HUD’s FHA 203(k) Q & A: http://www.hud.gov/offices/hsg/sfh/203k/faqs203k.cfm For area median home prices: https://entp.hud.gov/idapp/html/hicostlook.cfm Cost consultants can be found on HUD’s website: https://entp.hud.gov/idapp/html/f17cnsltdata.cfm For information on FHA mortgage insurance programs, visit: http://www.fha.gov/ For information on U.S. Department of Housing and Urban Development, visit: https://www.hud.gov/ Contractor license check: http://www.cslb.ca.gov/Contractors/

SPECIAL PRODUCTS DIVISION (Certification & Review Process) First mortgage SPECIAL PRODUCTS DIVISION (Certification & Review Process) 33 33

Certification Process Certification Requirement All FMC originators including Loan Officers, Processors, and Account Executives for Wholesale wishing to originate the FHA 203(k) program must be certified. As part of the Certification Process, you will be required to attend a FHA 203(k) Certification training, take the Certification Test and obtain a Certificate which will be required in every loan file submitted to underwriting for review. PROCESS: FHA 203(k) Certification Training is available on the FMC websites for self trainings. To request the test for certification: E-mail certificationhelp@firstmortgage.com Send back the Answer Sheet and worksheets to the same e-mail. The Loan Officers/Processors/Account Executive Certificates must be in the loan file submitted to Underwriting for approval 34

Retail Process Flow (Memo #B-12-06) Revised 8/6/2012 To ensure that all FHA 203(k) transactions are handled with careful reviews of the Contractors Bids to ensure they are thorough, bids are accurately quoted, contingency reserve is sufficient to complete the work, appraisers are congruent with the Bids, and the Borrowers and Contractors are fully informed of the disbursement of funds, ALL FHA 203k transactions are going to be reviewed by the Special Products Division For Wholesale, refer it to the Special Products Division as before (See “203K Updated Procedure Effective 8/6/12” e-mail issued on August 8, 2012 and Memo #B-12-06 for more details). SPECIAL PRODUCTS DIVISION Contact Information for submission and questions: Email: specialproducts@firstmortgage.com Phone: (800) 394-4778 35

Retail Process Flow cont’d… Revised 8/6/2012 PROCESSING: FHA 203(k) loans will be processed out of already certified Branches; otherwise, it will be processed out of Corporate Processing in Ontario, CA HUD Consultant: A HUD Consultant may be required on a Streamline 203(k) transaction Special Products will notify the Loan Officer and Processor of the HUD Contractor determination and their information if one is required and selected by Special Products HUD Consultant Fee: Initial Disclosures will always include a HUD Consultant fee (if needed) ranging from $400 up to $1,000 depending on repair amount and type of transaction If NO Consultant is required, the fee will not be charged 36

Retail Process Flow (Memo #B-12-06) Revised 8/6/2012 Submit the following to the Special Products Division: Prior to ordering Appraisal: CONTRACTORS BID (FHA Streamline 203(k) Transactions) to determine: Whether the transaction meets the FHA Streamline 203(k) guidelines If permits will be required. If required, loan cannot be done as a Streamline 203(k) Exception may be made on Roof permits by SPD If ALL utilities will be on prior to funding. If not, loan cannot be done as a Streamline 203(k) Validity of Bid, accuracy and completeness per HUD requirements If Contractor meets minimum qualifications for work to be performed Determine if a HUD Consultant will be required Purchase Contract 1003 SPD to inform Branch when the Appraisal is ready to be ordered 37

Retail Process Flow cont’d… Revised 8/6/2012 Upon Receipt of the Appraisal, send report to SPD to determine: Appraiser marked the correct repair Box on report based on transaction type The appraiser incorporated all items from the Contractors Bid on his report Did the Appraiser add any other required repairs to meet HUD MPS An “AS IS” and an “AS COMPLETED” value was given INCLUDE THE FINAL HUD-92700 for review prior to submitting file to UW INCLUDE ALL FULLY EXECUTED FHA 203(k) FORMS during this time for final review prior to UW submission SPD inform Processing when file is ready for UW Submission Prior to Docs: Send Approval and all 203(k) PTD conditions to ensure all underwriting requirements have been met and recommend what else may be needed/required LO/Processor to advise SPD of Borrower and Contractor phone #’s and preferred time/date for consultation LO/Processor to advise SPD once docs have been drawn to perform the required consultations with all applicable parties – Borrower, Contractors, etc. Prior to Funding: Prior to funding final clearance from SPD is required 38

RETAIL LOAN Step by Step CHECKLIST

Completing the 203(k) maximum worksheet (HUD-92700) First mortgage Completing the 203(k) maximum worksheet (HUD-92700)

Maximum Mortgage Worksheet

Example: Purchase Transaction EXAMPLE: Purchase of a 1-unit property with 96.50% LTV/CLTV Purchase and Renovation Costs Sales Price $ 100,000.00 After-Improved Value 130,000.00 Labor/Material 20,000.00 Contingency Reserve (10%) 2,000.00 Inspection – One at $150 150.00 Title Update – One at $100 100.00 Supplemental Origination Fee (greater of $350 or 1.5% or repair costs ??? Discount - NONE 0.00

Example: Refinance Transaction EXAMPLE: Refinance of a 1-unit property with 97.75% LTV/CLTV Refinance and Renovation Costs Existing Debt $ 95,000.00 As-Is Value 100,000.00 After-Improved Value 130,000.00 Borrower Paid Closing Costs + Prepaids 5,000.00 Labor/Material 20,000.00 Contingency Reserve (10%) 2,000.00 Inspection – One at $150 150.00 Title Update – One at $100 100.00 Supplemental Origination Fee (greater of $350 or 1.5% or repair costs ??? Discount – 1%

Eligible Expenses (Total Rehab – Line B-14) Eligible expenses to be included in Line B14 of the HUD-92700 (cannot exceed $35,000): Cost of Materials, labor, contingency reserve, overhead and construction profit (noted in each work item) Expenses related to the rehabilitation such as permits, fees, licenses, inspection fees by a qualified home inspector, inspection fees during construction by a HUD accepted inspector, lien protection fees for title updates (soft costs) Cost of rehabilitation may also include the supplemental origination fee and the discounts which the borrower will pay on that portion of the mortgage proceeds allocated to the rehabilitation

FMC Support WEB SITE TRAININGS SUPPORT Trainings for May 2015: RATE SHEETS TRAINING MATERIALS CALCULATORS TOOLS FORMS MARKETING TRAININGS First Mortgage offers FREE Weekly ONLINE Trainings See the FMC website for the May 2015 Training schedule Trainings for May 2015: 5/5 – FHA 203(k) Training 5/7 – FNMA HomeStyle Training 5/12 – FMC Product Overview 5/14 – HUD Handbook 4000.1 Overview 5/19 – CalHFA “Wholesale” Roll Out 5/20 – FMC Employees POINT Training 5/21 – FMC EEEM Process Training SUPPORT For Retail: Contact Loan Help For Wholesale: Contact A/E Scenarios Pricing Program Guidelines Product Support Loan Submissions Fees Trainings 45

On behalf of First Mortgage, thank you for joining today’s training and we hope the information provided will help you build your business! The main purpose of First Mortgage Corporation’s (FMC) training documents is to assist real estate and mortgage professionals in developing entry-level competence with loan programs. While FMC staff, employees, contractors and contributors take care to ensure the accuracy of the content of training documents, FMC makes no warranties as to the accuracy of the information contained within these materials. Furthermore, every user of this material uses it understanding that he or she must still conduct his or her own original legal research, analysis and drafting. In addition, every user must refer to the relevant legislation, case law, administrative guidelines, rules and other primary sources. FMC specifically disclaims any liability for any loss or damage any user may suffer as a result of information contained within this training material. While the information contained in FMC’s training material addresses guidelines and issues surrounding mortgage programs, these materials do not constitute legal advice. All non-legal professionals are urged to seek legal advice from a lawyer.