Impac Mortgage Corp. Correspondent helps those who want to expand their business with a non-delegated lending program that gives newly transitioned brokers to bankers access to Impac's broad suite of proven mortgage products. Some lenders refer to this type of arrangement as emerging banker or mini-correspondent, but those names diminish the true value provided by Impac's expertise in the lending field.
That expertise is critical, because the Consumer Finance Protection Bureau is wary of those who leverage these types of programs to evade certain consumer protection regulations. By working with Impac, newly transitioned brokers to bankers can ensure that they will be in strict accordance with all compliance issues.
The CFPB takes action
CFPB regulators issued a statement that specifically mentioned mini-correspondent arrangements that are structured to obscure their actions from consumer protection regulations. These include regulations that require broker compensation to be included in certain cost calculations and prevent brokers from directing borrowers to high-risk loans.
"Non-delegated lending helps newly transitioned brokers to bankers expand."
Some newly transitioned brokers to bankers use a mini-correspondent arrangement to circumvent these regulations, and the CFPB intends to crack down on brokers who are non-compliant. The organization will investigate these transactions and examine how the broker works with investors to fund loans.
Impac's compliant approach
Impac's non-delegated lending program is not a way to avoid regulations, and is instead a route for newly transitioned brokers to bankers to confidently grow their business while being backed by Impac Mortgage Corp. Correspondent, a leader in the correspondent lending space. The names "mini-correspondent" and "emerging banker" imply a temporary arrangement or that the loans made under the agreement will be small or unimportant.
Impac Mortgage Corp. Correspondent's non-delegated program is a long-term compliant option for newly transitioned brokers to bankers who want an expert partner in the loan-generation field. With products that suit any borrower, Impac's non-delegated lending system gives those individuals access to a large portion of the borrower market.