INNOVATIVE INTERNAL BLOG

Important Updates

Hometown Heroes

As I'm sure you've seen by now, Florida Hometown Heroes is coming back! We just wanted you to know the compensation allowed at the following lenders for HTH.

Compensation

Windsor is 1.50

UWM is 2.00

FBC is 2.00

Arive Login Issues

Arive is aware that there is an issue with their third-party SMS delivery provider for multi-factor authentication having delivery issues. Due to this, some users are having difficulty logging in.

In this event, users can still log into ARIVE by resetting their MFA and using an authenticator app to authenticate. Please go to support.arive.com and start a chat if you need help with these steps! (The chat feature takes a second to pop up, but it will appear in the bottom right corner of the support page).

25bps Lender List Surcharge

We recently rolled out a surcharge for adding new lenders. The reason we did so is because we already have over 60-70 lenders that we do business with. Most don't get much from us. Maintaining all those lenders (renewals, recertifications, requirements, requests, communications) is a full-time job in and of itself. In most cases when we add a new lender for an originator we wind up closing 1 or 2 loans with them and nothing more happens. To recover some of the expense related to maintaining this we decided the best plan was to continue to accept signing up new lenders, with the caveat that 25bps is deducted from the loan revenue.

You can view the updated list of 25bps Lenders HERE

Doc Magic Penalty Fee to be Charged if Sending Disclosures Incorrectly

You should NOT be generating a disclosure package in Arive unless it is correspondent and the investor requires us to. Repeat offenders will begin to be charged starting this month (August 2023). The cost will be $15 per incorrect package. Suzanne will only be sending out notifications to those individuals that are generating disclosure packages incorrectly.

All Correspondent files will be disclosed in Arive through the integration with DocMagic. This is already set up on your Arive site at NO COST to you. The only exceptions are if you send your Correspondent Loan File to EPM, Kind, Mega, NewRez, Plaza, Towne, UWM, and Windsor. You will be required to use these 8 lenders to do the disclosures for you - EVEN on Correspondent Loan Files.

All Brokered files will be disclosed by the lender.

Management Messages

Subject Line	Date Sent	Sent By	Email Message
Updated Wiring Instructions	3/11	Danna Kerns-Streett	Attn: LOs and Processors Please note, effective immediately, we have revised the point of contact for confirming wiring instructions to Plains Commerce Bank. The updated wiring instructions are attached. Please update your records accordingly. Please reach out to Danna Kerns-Streett if you need the updated instructions
Provident Funding HomeReady First Program (SPCP) ! - $10k in Grants!; STATE REFERRALS; COMPANY RECRUITING	2/21	Bryan Ehrlich	Hope you are having a great week. Business is starting to pick up! Even with rates a bit higher we are seeing steady activity. Take advantage of all the tools and products you can to capture ALLpossible business opportunities. Provident Funding HomeReady $10k grant: I wanted to share this with you. Scroll down below my email to see the information and details from PF Loans. Check your MSA to determine if you have an eligible client. Keep in mind that the 25bps new lender surcharge does apply to PF Loans. (see original email for the information about Provident Funding) STATE REFERRALS: You can earn an in-house referral bonus if you refer a borrower for a state you aren't licensed in. Reach out to me if you have an immediate need and I can refer your lead to an originator that is licensed in the jurisdiction for which you aren't. Unlicensed originators cannot participate in the origination of a loan, but they can benefit from an in-house referral bonus so long as it isn't greater than 49% of the commission earned by the state licensed originator handling the transaction. Innovative Mortgage of course must also be licensed in the jurisdiction. Innovative Mortgage Services is licensed in the following states: Licensed in Alabama, California, Colorado, Connecticut, Florida, Georgia, Louisiana, Maryland, Massachusetts, Michigan, Nebraska, New Jersey, North Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, and Texas. Click here to view our state license designations and license numbers. COMPANY RECRUITING: We need your help recruiting loan originators. Innovative's pricing and product leverage with investors, lenders and vendors (i.e. our LOS provider) increases as a result of having a larger base of producing loan originators. We do everything to pass the leverage benefits on to our LO's and contract loan processors. Consequently, when you help Innovative succeed by referring potential loan originators you are helping all our loan originators and processors succeed. Please email Andrew@InnovativeMLO.com or Bryan@InnovativeMLO.com if you have a recruiting lead to share. Name, number, email and background is always appreciated when you share an LO lead.
	2/16	Danna Kerns-Streett	Attn: LOs and Processors Hi Everyone, Happy Almost 3-Day Weekend! Just a reminder that our office will be closed on Monday, February 19 in observance of President's Day. We also have some important information to share about a new home for all of our processor resources as well as a PennyMac AUS Issue. Processor Resources We have added a folder full of Processor Resources to our website on the Resources page: https://www.innovativemlo.com/support-and-process-manuals-innovative-mortgage-services-inc Scroll down to the "Compliance and Processing Resources" section to access the resources. We will keep the folder updated as new information becomes available. image.png PennyMac AUS Red Flag Issue If you’re running a loan through PennyMac and the AUS at any point comes up with a potential red flag warning (and that would be listed on page one) the loan is not going to end up passing their approval. The most common instance we see is when the Loan property is listed as a TBD. However, there might be other issues that are making the loan a red flag. Therefore it’s important that when the loan originator submits the loan to PennyMac their AUS findings do not contain a red flag and therefore need to be carefully reviewed. The only solution when the AUS has a red flag is to rerun the AUS with a new case number, correcting the red flag item.
New IDS Password \| Arive Status \| Training Info from FSB Bank and NewRez	2/9	Danna Kerns-Streett	Attn: LOs and Processors Hi All, Happy Friday! Please make sure you read through all of this important info and see the attachments for the training information from our 2 training sessions yesterday with FSB Bank and NewRez. IDS Password The IDS password has been updated to: 2024Ims! The IDS website is for placing your order with Focus Fulfillment. If for some reason the password does not work on the first try you MUST reach out to our correspondent team at Innovative (Suzanne, Julie and Jen) to get the updated password. ARIVE Loan Status Please do NOT be move the status of any loan past Funded! Loans on the correspondent channel should not be moved past the status of closing- the correspondent team moves them to funded in real time when we fund the loan. Loans on the brokered channel can be moved to funded once the closing has occurred but we will move the status to Broker Check Received once we receive the wire/check. FSB Training Please see the following information from yesterday's presenters Mindy Stodart and Jan Manning as well as the attachments for the training materials. Please use this link for your clients to create a login/password to complete their application: apply.fsb-sbl.com/?referral_source=fsb_sbl_jan_manning We have included the basic application package they will be completing the information on. To prequalify TORCH loans (SBA 7a loans from $25k - $500k) we are generally looking for, An eligible use of proceeds Owner(s) score of 680 or higher E-Tran score of 165 or greater TORCH cannot be used for pure startup businesses or business acquisition. Buying a building, expansion-adding another store, working capital, equipment, and inventory are fine. Below is the list of documents required to complete the standard financial packet for underwriting’s initial review of the loan. Business Documentation Two Years of Business Tax Returns, 2021 and 2022 YTD Interim Financial Statements Profit & Loss Statement dated 12/31/2023 Balance Sheet dated 12/31/2023 Business Debt Schedule (template attached) Please remember credit cards, loans, including SBA and MCA loans, and any other tradelines that are paid monthly/weekly/daily. Business Asset List (template attached) Business Bank Statements for 3 most recent statement periods Additional Items based on Use of Proceeds How will these funds be used to help you grow your business? Personal Documentation for Each Guarantor Two Years of Personal Tax Returns, 2021 and 2022 Personal Financial Statement (template attached) Affiliate Information (Any entity owned 20% or more by the business or a guarantor) – Two Most Recent Business Tax Returns We look forward to working with you and appreciate the opportunity to assist your clients. If you have any questions regarding what is requested, I am available via phone or email. Thanks! Mindy is your contact with Torch (Small Cap) program. Please still copy me on all correspondence so I may assist with loan scenarios as needed. Mindy Stodart AVP, Relationship Officer ‑ TORCH First Savings Bank ‑ Small Business Lending \| www.fsb-sbl.com 702 North Shore Dr, STE 100 \| Jeffersonville , IN \| 47130 mstodart@fsbbank.net \| 513.235.5113 \| 812.670.4901 fax Thank you, Jan Manning AVP, SBA Lending Officer First Savings Bank ‑ Small Business Lending \| www.fsb-sbl.com 702 North Shore Dr, STE 100 \| Jeffersonville , IN \| 47130 jamanning@fsbbank.net \| 727.249.6304 \| 812.670.3699 fax First Savings Bank Small Business Lending Click Here to Send Me a Secure Email Instructions to Send Me a Secure Email Click Here to Send Me a Large File NewRez Training Please see the attached PowerPoint from James from yesterday's training session. James Keener / ORLANDO, FL! 😊 Senior Account Executive Wholesale Account Executive since 1996! A picture containing text, clipart Description automatically generated M 865.755.7116 James.Keener@newrez.com
CIC Credit, UWM's Soft Pull, VOEs, Upcoming Training	1/31	Danna Kerns-Streett	Attn: LOs and Processors Happy last day of January! I have a lot of information to share with you today so please make sure you read through this entire email. CIC Credit Please see the most updated pricing sheet attached to this email. Here is a message from Theresa McCoy, our AE with CIC: Hello Innovative Staff Members, CIC has negotiated the Rate Plan for 2024. Our management team has agreed to make a setting change that will also bill each user daily. Most users do use the smart pay link, that does allow the consumer to pre-pay for the report or use a card to pay for each transaction. Smart Pay can only be completed every 30 days. Many times, file changes are needed to correct name, address, social or Date of Birth, Re-pull of a bureau & Supplements. This change will resolve the payment on those changes. If you wish for the fee to be charged to your consumer, please do provide the billing details when additional customer service is needed. Please do feel free to reach out to your account manager Theresa M McCoy for setup & any questions. If you have any questions about CIC please reach out to Theresa directly. UWM's Soft Pull Option There is a soft pull option that UWM will pay for. However, on correspondent files we need a lien and judgement page which will not be a part of this report. You will need to pull one bureau report so that the lien and judgement page comes over. This is only on correspondent files and UWM is aware of it but advised that this is the only solution to obtaining this report. You can also check with your credit provider to see if they will allow you to run a lien and judgement page only. If you have any questions about what is required for correspondent files please reach out to the Correspondent Team (Suzanne, Julie, and Jen) VOEs - Employment Information In Arive Just a friendly reminder to please try and make sure that the employer's phone number is accurate in Arive. Lately we've seen an increase in borrower's putting their own cell number in for the employer contact number. This causes an issue when processors and/or our correspondent team are reaching out to do the VOE. Upcoming Training with FSB Bank Mark your calendars for our next training session with FSB Bank on Thursday, February 8th from 11:30am-12:00pm ET. The training will focus on SBA 7(a) Small Cap (Torch) Commercial Business Loans. I will send out the Zoom link next week for those that would like to attend. Please see original email for above mentioned attachments. If do not have the original email please reach out to Danna Kerns-Streett for the attachment or refer to our website.
GUS Access Instructions	1/29	Danna Kerns-Streett	Attn: LOs and Processors Happy Monday! Please see attached for instructions on how to sign up for GUS Access. The Gus Access Instructions can also be found on our Resources page. Please see original email for above mentioned attachments. If do not have the original email please reach out to Danna Kerns-Streett for the attachment or refer to our website.
2023 Form 1099-NEC	1/29	John Tredo	Attn: LOs 1/29/24 - Good morning. The 2023 Form 1099-NEC have been processed. You will be receiving an email from our vendor, TAX1099, with instructions on how to download. 1/29/24 - For further clarification- Please address all emails to me and NOT Bryan. You will be asked to login to access the form. Here is a sample of the email: 1/31/24 - Good afternoon- After working with our vendor, Tax1099, any issues you have encountered in retrieving your 2023 Form 1099 should be resolved now. Please retry this afternoon/evening. If you still have any problems, please email me directly.
Arive Login Issues, Credit Pricing	1/23	Danna Kerns-Streett	Attn: LOs and Processors Hi Everyone, If you are having issues with logging into Arive, please use our original link to login: https://250769.myarive.com It's my understanding that you'll need to use that link to login for the foreseeable future as older links and previous links that were bookmarked won't work due to the patch they put through last night to try and fix the MFA issues they were having yesterday. If you need help, please use the chat widget at the bottom right of the login screen or support.arive.com. Also, please see the attached pricing sheets for Sarma and Credit Technologies. Our Third Party Resources page has already been updated with both sheets. Please see original email for above mentioned attachments. If do not have the original email please reach out to Danna Kerns-Streett for the attachment or refer to our website.
Arive Files, CFPB Imposter Scam, Logan Training	1/16	Danna Kerns-Streett	Attn: LOs and Processors Hi All, Please read the entirety of this email for important information. Arive Files Please make sure ALL loans including HELOCS, non-QM, and commercial loans are loaded into Arive. The file should be started in Arive when the borrower makes the application (even if the application is done somewhere other than Arive). The dates and status need to be updated in real time. CFPB Imposter Scam Please read this and share it with your clients! consumer financial protection bureau Beware of new CFPB imposter scam This week, we confirmed that scammers are using CFPB employees’ names to try to defraud members of the public. We’ve heard from people, specifically older adults, who received phone or video calls. We can’t say it enough – the CFPB will NEVER contact you and ask you for sensitive information or to pay money. This includes never asking you to pay an upfront fee or taxes, or telling you that you’ve won a lottery, sweepstakes, or class-action lawsuit. We also won’t ask you for personal or sensitive information before you can cash a check we’ve issued. The latest phone and video scams may include: A phone or video call or an email from an imposter claiming to be a CFPB or other U.S. government official. Messages or calls notifying you of an opportunity to participate in a class-action lawsuit, or that you’ve won a lawsuit or owe money you didn’t expect. Being told you must first pay taxes or another upfront fee to collect the money. They may continue to find “reasons” for you to pay more fees or taxes. It is all part of the scam. If you’re contacted by someone from the CFPB and want to confirm whether it’s real or a scam, call our consumer call center at (855) 411-2372 between 8 a.m. and 8 p.m. ET, Monday through Friday. Logan Finance Training Materials Here is the information that Matthew sent to me after the call today. Please reach out to Matthew directly if you have any questions! For credentials: Forms (hive.com) For training session on the portal: Click here to schedule Submission Portal Training Thanking you in advance, Click: Products Click: Pricing Portal (no credentials needed) Check us out on LoanSifter,LoanEx,Lender Price Click here to schedule Submission Portal Training Matthew A. Sangiuolo National Sales Executive C: 772-485-0349 matts@loganfinance.com scenarios@loganfinance.com www.loganwholesale.com Logo, company name Description automatically generated Please see original email for above mentioned attachments. If do not have the original email please reach out to Danna Kerns-Streett for the attachment or refer to our website.
Assigning AUS findings to PennyMac, Updated Correspondent Lending List	1/11	Danna Kerns-Streett	Attn: LOs and Processors Hi Everyone, Below you will find instructions on how to assign AUS findings to PennyMac and the link to our Updated Correspondent Lending List. Correspondent Lending List We've updated our correspondent lending list. Please make sure to reference all columns when writing a correspondent loan including the LE/disclosure column which indicates whether disclosures should be done in Arive or through the investors portal. You can access the list here or on the Correspondent and Wholesale Lending page of our website. Assigning AUS Findings to PennyMac PennyMac does not have an AUS system in their web portal. As a result, we are to ASSIGN the FINAL AUS to PennyMac through our AUS on Arive or directly from the Fannie Mae or Freddie Mac websites. Here are the steps you will need to take IMPORTANT: The final AUS that you assign needs to match the final CTC approval. So you should not finalize an AUS with a TBD. Before you finalize the AUS and Assign to PennyMac, ensure the terms are the same that have been approved at PennyMac *NOTE: There could be several PennyMac assignment options within Arive and the Fannie Freddie online systems. This is due to the assignments having to go to the NON DEL side or the WHOLESALE side. Make sure you see the Lender ID numbers below associated with the PennyMac listing that you are assigning your AUS to PennyMac Fannie ID 27007 PennyMac Freddie ID 153780 1. Run your (1) One Click AUS on Arive or individually run your (2) Fannie DO or LOG INTO Freddie LPA https://www.freddiemac.com/ (DO NOT CLICK THE RUN ARROW that is numbered 3 Below ) 2) If you decide to use Fannie Mae and you ran the One Click Option, you will need to re run the AUS by selecting the RUN tab next to Fannie Mae - image.png FANNIE MAE STEPS Once you click on the RUN tab from Step 2 above, you will see the following screen pop up Your Credit Account, CASE ID and Fannie Mae user ID will all pre populate 1. Select the dropdown arrow on SUBMISSION TYPE and select FINAL 2. That will open up an option to select the lender to finalize it to 3. Select the blue highlighted PennyMac option below - PENNYMAC LOAN SERVICES ,LLC DO NOT SELECT THE ONE THAT SAYS TPO NEW Then you are done - It's that simple 3) If you decide to use Freddie Mac and you ran the One Click Option, you will need to re run the AUS by logging onto the Freddie Mac online portal - https://www.freddiemac.com/ (Do NOT run Freddie Mac on Arive) FREDDIE MAC STEPS Login to https://www.freddiemac.com/ Select Single-Family Division and then Single-Family Division again on the dropdown Hover over Technology and then select Loan Advisor The next screen will appear and you will select Loan Advisor Login * YOU WILL NEED TO GET LOGIN CREDENTIALS FROM SUZANNE EHRLICH- ONLY REQUEST IF YOU HAVE A FREDDIE DEAL TO ASSIGN - IF YOU CANNOT DEMONSTRATE THAT YOU HAVE A LOAN TO FINALIZE WE WILL NOT GIVE YOU THE CREDENTIALS*** You'll see an MFA screen next - complete that You will then see the screen below and you will click on the Loan Product Advisor OPEN button Type in your LP AUS Key from your Findings The LP AUS Key is at the top of your Feedback certificate When you find your file, 1. Click the Radio button and 2. Hover over the head and shoulders icon to ASSIGN LOAN On the next screen 1. Select the 3rd party company role on the loan and it will be SELLER Them, 2. start typing in PennyMac - Penn is enough 3. Select the PennyMac Loan Services, LLC ( 153780) and then click on Assign YOU DID IT! If you have any issues please reach out to management.
Processing Duties, PennyMac Fulfillment Info	1/11		Attn: Processors Hi Processors, Please see the attached two documents regarding Innovative's expectations around processing duties as well as the PennyMac fulfillment information you'll need when working on PennyMac files. Please reach out to Suzanne if you have any questions or concerns. Please see original email for above mentioned attachments. If do not have the original email please reach out to Danna Kerns-Streett for the attachment or refer to our website.
Please read this complete message to avoid penalties!	1/5	Bryan Ehrlich	Attn: LOs and Processors Good afternoon, happy New Year and happy Friday! I have a few brief but important announcements that require your attention. Self-processing Requirements: Just a reminder that ALL requirements must be completed when self-processing a transaction. Otherwise the transaction will be subject to a $500 penalty fee. There is ZERO tolerance with regard to this penalty, so please observe all the requirements. The requirements can be found by clicking this link and scrolling to the section of the portal regarding self-processing. 25-Bps New Lender Surcharge List: Please keep in mind that some lenders may be listed on the 25-Bps New Lender Surcharge List (click the link to view the list - it's also on the company portal here). Since so much time and expense with regard to lender applications, renewals, recertifications, liability (yes, lenders that we broker to can demand Innovative repurchase a loan for fraud, misrep, early payment default, or other reasons) and to better manage new lender requests, infrequently used or new lenders fall on this list. Lenders will be removed from the list once they meet the minimum threshold (at least 6-funded transactions in the last 12-months). Be sure to check the list especially if you are writing a loan with a lender you haven't previously used. The list will be regularly updated as needed. State License Renewals: Some lenders and investors may request that the company's renewal history be provided to clear conditions pertaining to state licensing. Please forward the Renewals History to them as necessary. The Renewals History can be found here on the company portal at the top of the page. Marketing and Advertising: Once again a reminder regarding marketing and advertising. The policy can be found in our company's Compliance Manual by clicking this link. I can't emphasize enough that this INCLUDES ALL SOCIAL MEDIA MARKETING. You are exposing yourself and Innovative to stiff fines and penalties if the state regulatory agency audits Innovative and fails to find an archive record of marketing and advertising of your business related social media posts. Just take a screen snip of the post and email it to me for approval and archiving. It is that simple. Training Opportunity: Next week: Thursday, 1/11 @ 1:00pmET ARC training focused on how to capture and write more business. Thank you for your attention to and observance of these messages. Have a FANTASTIC weekend! Please see original email for above mentioned attachments. If do not have the original email please reach out to Danna Kerns-Streett for the attachment or refer to our website.
Focus Fulfillment and PennyMac	1/5	Danna Kerns-Streett	Attn: Processors Hi Processors, Please read through the ENTIRE email from Suzanne below regarding Focus Fulfillment and PennyMac. If you have any questions, please email Suzanne and Julie. ---------- Forwarded message --------- From: Suzanne Ehrlich <suzanne@innovativemlo.com> Date: Mon, Dec 18, 2023 at 4:26 PM Subject: Focus Fulfillment and PennyMac To: Danna Kerns-Streett <dannaks@innovativemlo.com> Focus Fulfillment This is a TWO- STEP process. Please READ both Steps. Julie or Suzanne need to approve your Initial CD prior to release to the borrower. Please make sure ALL LE's AND COC's are uploaded to Arive for review. If you complete this correctly you will receive an email from Focus indicating they have your request. You can place your order once you have an approved with conditions on the loan file. Please only submit loans that you will be able to clear the conditions to obtain a loan approval 1- You need to UPLOAD the Vendor MISMO 3.4 from Arive into IDS. When you are in the file in Arive, please go to the three ellipses in the far right corner. Select EXPORT MISMO 3.4 XML. You will then be able to select the XML VENDOR file This is the ONLY file that will export your fees. You will get the below message- please proceed This export is implemented to support generating disclosures via Doc Vendor such as Doc Magic. The file exported from this should not be imported back in ARIVE as it will error out. doc login- https://www.idsdoc.com user name- Suzanne@IMSI Password- Ims2024! Once you are in IDS select IMPORT to import the “Lender” 3.4 MISMO file from Arive - Select MISMO XML from the dropdown to upload and save file only- do NOT do anything else You will then see your loan in the Loan Files 2- You need to place an order with Focus Fulfillment in order to have them release the Initial CD, Final CD and closing documents The site to place your order is - focusdocs.com. Please select “place order”. The tab is at the top right of website Add IMS correspondent team to the email distribution list for the loan file. You will receive an email from them confirming the order has been received. https://focusdocs.sharefile.com/ - to upload documents once Focus has created a folder Login- Julie@innovativemlo.com Password- Inno2023! **Currently Focus will be asking you for the attached documents to be uploaded to this share file above. We are currently working with them to allow them Arive access so that they can export them directly. Please note that Focus is acting on behalf of Innovative so they will ask for the items attached in the email. Processors are NOT responsible for approving the Final CD as that will come from the loan officer AND Innovative. Please make sure all LE’s PLUS all CD’s contain the same loan number. This is your responsibility as you will be placing the order to the fulfillment center. You will need to provide to the fulfillment center a Final 1003 that reflects the accurate data on the AUS final submission. The Final AUS system should reflect PennyMac Loan Services - this is done on DU within Arive or done on LP on the LP website with the LO’s logins. You will need to provide to the correspondent team a VVOE within 10 days of the loan funding date. Please note that Innovative will be reviewing all items along the way to make any corrections as needed. The fulfillment center will issue the Initial CD to the borrowers for signatures. PennyMac Specific Items DU- The Final AUS system should reflect PennyMac Loan Services - this is done on DU within Arive or done on LP on the LP website with the LO’s logins. Mortgage Insurance- You are responsible for ordering the MI directly on PennyMac’s site. You are responsible for running the MI Cert any time there is a change to the loan parameters (loan amount, DTI, FICO, ect). It is important that the MI cert matches the Final loan parameters. Please make sure a copy of the MI cert is always sent to underwriting as well. Please find information attached to assist you in this
Early Payoffs (EPOs)	1/3	Bryan Ehrlich	Attn: LOs and Processors Good afternoon and happy New Year! I hope this email finds you well. Just a quick reminder that as rates settle down there will be a higher likelihood of borrowers refinancing and paying off their existing mortgages. This could lead to EPOs. Innovative is liable to EPO penalties, just as it is liable to repurchase loans with fraud, misrep, or early payment defaults on the broker and correspondent channels. To minimize the possibility of an EPO be sure to have a brief conversation with your borrowers regarding the implications to you and Innovative. Ask them to advise you if there's any possibility of the loan being paid off before the EPO period expires (which varies from lender to lender and investor to investor). Look out for EPO red flags, such as large sums in the bank, pending home sales, possible inheritance, etc. Loan processors, keep an eye out for these flags and alert your LO if you have reason for concern. Ignoring possible EPO flags won't make them disappear and go away. Remember, LO's are liable for EPOs and commissions are at risk of being clawed back. Here's a recent change that Windsor made to its EPO policy. Note that any yield spread credit given to the borrower is part of the EPO penalty in their latest broker agreement revision. For example, if you brokered a borrower paid transaction and the borrower had been credited 10k in yield spread, Innovative would be liable for that amount in an EPO (and by proxy the LO). Be conscious of these things and bring them to Innovative management's attention where appropriate and before loans fund. It is better for everyone to address these issues in advance rather than after the fact.