Pricing Exception Category Detail Requirements

Competition

Rate Lock Extension

Circumstances outside of FCM’s Control

ATR/QM Points and Fees/High-Cost Issues

Description/Examples:

To submit a Competition PE request, you are required to document what you used to validate the competitor’s pricing.

For example: LE, Pre-Approval letter, Pre-Qual letter, Pricing Special Flyer, email or verbal confirmation. Only validated pricing can be used for a Competition PE.

Description/Examples:

Description/Examples:

These scenarios must be reviewed by Branch Manager, RPM, Scott Matuk, or Compliance for alternative solutions prior to approval. In many cases there may be better options.

Requests such as competition, LO did not lock prior to market shift, borrower changed loan products, trying to make cash to close zero, are NOT circumstances outside FCM’s control and will be rejected.

Description/Examples:

These scenarios must be reviewed by Branch Manager, RPM, Scott Matuk, or Compliance for alternative solutions prior to approval. In many cases, PEs are not required, and an alternative solution can be used that may be less expensive.

Loans should never be quoted or locked with a known ATR/QM/High-Cost Fail. All loans are required to pass regulatory tests as originally locked. A PE is not allowed to cure a loan that never passed these tests.

What is Required:

· Full name of Competitor

· Rate being offered by Competitor

· Discount Points being offered by Competitor

· Lender Credit being offered by Competitor

· Additional relevant information

· Amount of Pricing Exception requested

What is Required:

· Specific details explaining why rate lock extension is needed

· Specific details explaining why the rate lock extension was not charged to borrower

· Additional relevant information

· Amount of Pricing Exception requested

What is Required:

· Specific details of situation outside FCM’s Control (verified system issues, SCRA, Acts of God, Borrower’s personal circumstance changes)

· Additional relevant information

· Amount of Pricing Exception requested

What is Required:

· How much was the ATR/QM/High Cost over the limit?

· LO cannot quote, offer or lock a rate/price that does not pass ATR/QM/High-Cost, how did this error occur?

· Is changing the rate an option, if no – why?

· Could seller paid credit be used instead of a concession?

· Additional relevant information

· Amount of Pricing Exception requested

FCM Error

Temporary Pricing Special

Customer Service Issue

FCM Employee Loan

Description/Examples:

These scenarios must be reviewed by Branch Manager, RPM, Scott Matuk, or Compliance for alternative solutions prior to approval. In many cases, PEs are not required, and an alternative solution can be used that may be less expensive.

Requests related to competition and rate lock extensions will not be approved in this category.

Description/Examples:

This is almost exclusively used by Wholesale for various pricing specials.

Retail may use this category – but only if the EBM Owner has received approval in advance by Compliance. Pricing Specials must meet specific compliance criteria.

Description/Examples:

These requests are due to a customer expectation issue that occurred during the loan process that was not anticipated upfront.

Requests related to competition, rate lock extensions, missed CIC opportunities, disclosure errors, etc. will not be approved in this category.

Description/Examples:

This category is only used for Employees loans in accordance with the Employee Loan discounts as noted in the FCM HR Handbook. Loan originated must be in the name of the Employee and flagged in the system as an Employee Loan.

What is Required:

· Specific details of the error and how/why it occurred

· Was this a system error or user error?

· Was this a disclosure error or an operations error?

· If system error, has a Help Desk ticket been submitted to fix?

· Additional relevant information

· Amount of Pricing Exception requested

What is Required:

· What is the special

· How much is the special

· Dates special will run

· Confirmation special was approved by Compliance

· Additional relevant information

· Amount of Pricing Exception requested

What is Required:

· Provide specific details on the customer service issue.

· Was this issue preventable?

· Additional relevant information

· Amount of Pricing Exception requested

What is Required:

· Employee Name

· Confirmation employee meets the requirements outlined in FCM HR Handbook

· Confirmation originating LO is Authorized to work on Employee Loans

· Additional relevant information

· Amount of Pricing Exception requested