ACUMA ONpoint

Navigating Mortgage Compliance: Understanding Recent UDAP Changes

Team ACUMA Season 3 Episode 85

Regulatory changes have been coming fast and furious in the credit union mortgage industry, leaving many wondering what's still required and what's been relaxed. In this eye-opening episode, Amanda Phillips, General Counsel and EVP of Compliance with ACES Quality Management, guides us through the regulatory maze with remarkable clarity.

Amanda brings her extensive compliance knowledge to bear on one of today's hottest topics: the withdrawal of policy statements regarding abusive acts and practices (UDAP). We explore what this means practically for credit unions, particularly regarding post-closing and servicing operations. With her unique ability to make complex compliance issues accessible, Amanda helps us understand that while certain guidance has been withdrawn, core obligations remain.

The conversation takes a deep dive into PMI termination requirements, distinguishing between automatic termination (based on original loan values) and borrower-requested termination (potentially based on current valuations). We examine the potential pitfalls of online property value estimates and how they relate to PMI obligations. This section alone could save your credit union from serious compliance headaches!

We also explore how the withdrawal of guidance on "unauthorized and unreasonable fees" impacts what credit unions can charge. Amanda emphasizes that transparency remains the key, even as regulatory frameworks shift. Her insights on loss mitigation rule changes provide critical context for servicing teams navigating post-pandemic realities.

Sponsored by Consolidated Analytics

Speaker 1:

The views and opinions expressed in this podcast do not necessarily reflect the views or positions of Acuma, its board of directors, its management staff or its members. The podcast discussion presented is conversational in nature and for general information only.

Speaker 2:

Hello and welcome to Aqua's On Point Podcast, a series focused on sharing the stories of people who are making a positive impact in the credit union mortgage industry. I'm your host, Peter Benjamin. Before we get to our episode, just a quick word from our sponsor.

Speaker 3:

This episode is brought to you by Consolidated Analytics, helping credit unions make smarter mortgage decisions, from origination to servicing and beyond. With expert valuation, risk management and compliance solutions, they provide the insights you need to protect your members and grow your portfolio with confidence. Whether it's due diligence or a collateral risk assessment, they help you navigate the market with ease. Learn more at consolidatedanalyticscom.

Speaker 2:

Welcome to the third episode of our Compliance Summer miniseries, where each episode will feature an intimate conversation with people who I consider to be experts in their field and supporters of the credit union movement. As a reminder, with each of these episodes, it's our goal to take a deep dive into various compliance topics that are impacting and reshaping the credit union mortgage industry. Our next guest in the compliance miniseries is Amanda Phillips, General Counsel and EVP of Compliance with ACES Quality Management. Mandy, how are you doing today?

Speaker 4:

I'm doing great, Peter. Thank you for having me.

Speaker 2:

Oh, it's absolutely our pleasure. I mean, you are most certainly a regular within the Acuma circuit. A familiar face, a familiar voice. The Acuma circuit, a familiar face, a familiar voice, so we are thrilled to have you here as you impart your words of wisdom on our listeners. I think it's gonna be a great conversation. More to come on that, but before we get to it, as always, got to bring Justin into the conversation. The Hawk. What is the latest and greatest happening over at Acumen, by the way? How are you doing today?

Speaker 5:

I'm good, peter, how are you okay? You're okay. Okay, I like that alright you gave me nothing.

Speaker 5:

That kind of hurts. I'm sorry, man, it's just my moment to like get that dialogue going. I know I'm just tired. I mean it's not like you haven't been on the road, for you know a few times To like get that dialogue going. I know I'm just tired. I mean it's not like you haven't been on the road, for you know, a few times this year already and we put on three in-person events that were spectacular and I think our members had a lot of good things to say.

Speaker 2:

So I know it's just the body hurts, tired, can't get enough sleep. Just, I don't know what it is, man.

Speaker 5:

Keep pushing, keep pushing. You know what? I totally understand that, and but the good thing is is now we're in the midst of the summer and so you get to kind of take, as Krista would like to tell us all, the July reprieve, which does not exist.

Speaker 2:

No such thing, I'm back on the road, like next week.

Speaker 5:

Exactly See. All right, there we go. I love it. Well, here at Acuma we are busy. We have Make your Mark annual conference coming up in just a couple of short months, so September 21st to the 24th I kind of stumbled on those dates, but that's the 21st to the 24th. We're going to be in Denver, colorado.

Speaker 5:

So if you haven't seen anything from us about that, one, I'm not doing a good job. But two, what's going on? Come on, follow our socials. We're doing great, but we're going to have an amazing event planned. The agenda is coming together very nicely. Peter keeps adding stuff to it, as always, just to make it even more for all you guys out there listening. So it's going to be an exciting event and we can't wait to share that with you.

Speaker 5:

Other stuff we have going on we have our networking and educational opportunities. So our newly launched servicing network is going to have their first meeting tomorrow, which is super exciting. So if you're in the servicing side of the mortgage industry, be sure to check that out. Um, we have a great group of co-chairs lined up for you, so I'm certain that you're going to have a great time with that meeting. Our Marketing Network Q3 meeting that's coming up in just two weeks, so it's going to be happening on July 23rd, so head over to the Acumen website to register for that. And then, of course, we have our webinar series, our Fast Tracks and Inside Tracks, which are happening all year round so we can keep that education going on our ongoing basis. And then our favorite I can't say our favorite, because everything's our favorite, but our near and true dear to our heart our On Point podcast, which just keeps the fun going and the education all year round as well.

Speaker 2:

Oh yeah, you know, going back to the servicing network, one, it's a good segue to being part of the conversation today. But but two, you know, when you look at the history of Acuma, you know the servicing component, that servicing education, is something that's been, you know, missing from from Acuma, something that's been. You know that we really haven't focused on, it's always been sales and originations and operations. So really excited that this is kicking off. You know the three chairs that we picked are truly subject matter experts in their field. I think it's going to benefit our members. I think they're going to walk away better educated, better connected. And again, just one more step towards us. When I say us, I mean the Acme community becoming more well-rounded in everything that we do right, not just focusing on sales, but it's the entire mortgage ecosystem and the entire process. So really looking forward to that network just kicking off tomorrow.

Speaker 5:

Yeah, and the fun thing about that network also is it's one that grew. I guess it kind of grew organically within the Acuma community, yep, like they became one of the bigger communities within our, our community online forum and just hearing from our members is like an you know us putting it all together and trying to answer the the need that clearly existed for them. So I'm excited to see it come to fruition, as always.

Speaker 2:

But you know, yeah, that one was definitely a member request, like they definitely requested that one. They ask we listen, we put it together and here we go.

Speaker 5:

Yep, exactly Awesome man, Thank you so much. Of course my pleasure.

Speaker 2:

All right, Mandy, back to you. Obviously, we have a great conversation on compliance, which is obviously why we are here, and you know, I imagine we're going to talk about a whole bunch of different stuff.

Speaker 4:

There's not a shortage of things to talk about.

Speaker 2:

I'm sure they're definitely keeping you on your toes as of late, but you know, before we get to that, get to that, I always start with the first question and with the same last question. So I'm not going to go away from that. So, first things first. First question is, as always, what makes Mandy Mandy? So who is Mandy? It's again. The Action 1.0 podcast is a people piece. People make a positive impact in our industry. That's always the first question. So for the people who do not know who Amanda Phillips is, who is Amanda Phillips?

Speaker 4:

Amanda Phillips is a Coloradoan with three kids from elementary school, middle school and high school. For dogs, yes, I am a glutton for punishment.

Speaker 2:

There is such thing as a crazy dog lady, but I guess it might've happened.

Speaker 4:

Three of them are puppies, so there are two or a year old and one is 10 months old. So, yes, there's a lot going on around here.

Speaker 2:

That is a lot. That's a lot going on around here. Okay, that is a lot.

Speaker 4:

That's a lot. I'm a total compliance nerd, but I also love people and I love hanging out with my credit union peeps always.

Speaker 2:

Okay, love it, love it Okay.

Speaker 4:

Let's see, I love skiing and the beach, so those are total opposite things. So I live in Colorado so we can ski easily and then we like to go to the beach on vacation. What else about me? I've been in the mortgage industry longer than I care to admit. Before I became a boring compliance lawyer, I was on the business side, so I've been sort of sitting in the seat of all of our mortgage folks that are doing the day-to-day, which I think is it provides an interesting perspective for compliance professionals. Right, like most compliance people haven't done the thing, and so being able to know, like, what people are going through helps in sort of implementing regulations on an operational level. Okay.

Speaker 5:

Okay, I love it on an operational level Okay. I love it. I gotta know something. Do you surf when you go to the beach? I don't. As I say, you're kind of like the modern day. Johnny Tsunami, you know, there we go.

Speaker 4:

No, but my oldest, my high schooler, wants to learn how to surf.

Speaker 5:

Yeah, so he'd be like the reverse Johnny Tsunami. Yeah, I like it.

Speaker 4:

We might have to let him learn, yeah.

Speaker 2:

All right, I dig it, I dig it, all right. So thank you very much for walking, walking us through that now. So I've admittedly been amazed by you For much longer than my time here at Acuma, and I'm going to come off like a little stalker and I don't mean to yeah, uh-oh. But a long time ago, you know, I worked at a credit union and that credit union was looking for an LOS and I think before you came to ACES or went over to ACES, you worked for Accenture, right.

Speaker 4:

Yeah, so right before ACEs I was actually outside counsel at Ballard's Bar. But before that I was at Accenture. Yeah.

Speaker 2:

Which has an LOS right.

Speaker 4:

They do.

Speaker 2:

And I specifically remember, specifically remember, being in my conference room and it actually hit me.

Speaker 2:

We were talking, we had our sales rep, you know, in the sales room and we were vetting this, this LOS, and we were had major concerns about compliance and the sales person was like, well, let's get, you know, our, our head of compliance on on the phone and we had this pretty much two hour long conversation with their head of compliance, which happened to be you, and I knew, from that moment forward, all of my concerns about compliance.

Speaker 2:

Just after a two-hour long conversation with you and I know it sounds ridiculous, two-hour long conversation I knew that that was the LOS that, from a compliance standpoint, we would be okay with. And I was absolutely blown away by you, by your general knowledge about everything, that that was going to be the right system for us to go with. So, again, I was just blown away by your knowledge, everything. It was a great conversation. So I specifically remember that how you stood out above everyone else, but you're just general knowledge. So I, I I wanted to mention that because you, even to this day, you're still someone who very much impresses me about your knowledge. But the way you you engage people because compliance isn't exactly the easiest of things to keep people's attention about.

Speaker 4:

It can be boring.

Speaker 2:

I was trying to be nice about it, but yes.

Speaker 4:

Well, look, unless you're a compliance nerd like me and you think it's super fun and fascinating and you want to talk about it, most people are like, oh, let someone else do that. And by the way you've never told me that story.

Speaker 2:

It's true, it's true, um, and it's you. You do a very good job, which is one of the reasons why we wanted to have you on this podcast, because we want people who can take a very difficult conversation, a very difficult topic, and make it easy for people to understand. So I think it's so important, right? That's why people don't care about compliance right, or a compliance topic, or a regulation or an act or something like that, because they get lost in the weeds, they glass glass over and they just stop paying attention.

Speaker 4:

It's very dense.

Speaker 2:

It is, and you do an excellent job.

Speaker 4:

Well, thank you.

Speaker 2:

Of clearly spelling it out, and you're extremely knowledgeable, and I think this is why you keep coming back.

Speaker 4:

I love coming back, so thanks for having me. I try to make these things understandable, right? If you just hand somebody a member or one of the team members from one of our credit unions of 800 page regulation, they're going to look at you like I know I don't want to.

Speaker 2:

Exactly, exactly, I know I don't want to exactly, exactly, and there, and trust me, there are some that are like the one that you and I had a great conversation on back, and this is what I want to say was oh, maybe like uh, 2018, maybe um 2020, 2018, where you I guess you were at a center back then 18, 19. Yeah, okay, um 2020, 2018, where you, I guess you were at a center back then 18, 19, maybe, yeah, okay, I want to say it was like trid.

Speaker 4:

Oh, probably.

Speaker 2:

Um, cause everyone was still so confused, Right and I I at that point in time I had just come off, um, you know, working for an IMB where I helped them implement Trid or get ready for Trid, and so I was still very fresh and knowledgeable off Trid and the credit union I worked for was still very confused about Trid and you and I had a great conversation, and so that's a good example of how people still don't get tread.

Speaker 4:

They just don't oh no, it's been 10 years and we're still talking about I mean, I just emailed over my old procedures to somebody.

Speaker 2:

I'm not joking around. I'm not joking around, I keep everything like in Google and in a Google drive. I just emailed my procedures over to somebody because they were going through an audit and they were hit for trid and I was like here are some trip procedures, just just use them, they're good. I use them in a community bank and I use them at my last credit game and they're good, trust me. Anyways, I wanted to pay you that compliment. We're getting off track. So.

Speaker 2:

So I think one of the things we want to talk about is, you know, in today's podcast is diving into. You know, there's been a lot of changes that have happened lately. You know, within this, administrations and you know regulations being changed, whether it's at the CFPB or NCUA or FHFA, I mean, you name it. I think. I think right now, our industry is, I don't say a moving target, but the way we need to operate is ever evolving, and one of the things we want to dive into is the withdrawal of policy statements regarding the abusive acts and practices.

Speaker 2:

Yeah, and we can shape it up to be UDAP, right, but one of the things I kind of sort of want to focus on is, you know, maybe the post-closing side of things. It doesn't necessarily have to be servicing, it can be servicing, but anything we'll say closing, defunding and beyond, because all too often there's a lot of things that happen that lenders whether it's, I'll not say, credit unions just aren't doing. A good example would be the failing to terminate PMI right, I think there's a lot of components to it that we're just not watching and I think we need to dive into these things because we could get in a lot of trouble. So I'll let you take it from here and I'm gonna shut up no, you're fine.

Speaker 4:

so, among among other things that have been rescinded recently um, they did rescind the um guidance on udap. Also, if everybody hearkens back to 2022, we had the exam manual update that dropped that sort of shocked our the rescission of the guidance. In April. We had the CFPB and the plaintiffs who had sued to pull that out of the exam manual agree to a joint stipulation dismissing that appeal. So we've not only had the rescission of the guidance statement but now we've had the exam manual litigation completely dismissed with prejudice.

Speaker 4:

So there's definitely a shift in philosophy at the Bureau around UDAP. But does that mean that we just don't have to worry about when we terminate PMI? We just don't have to worry about what fees we charge? We just nah, doesn't matter anymore. I I would say no. Um, you know we still need to follow the law and there are specific regulations related to automatic termination of PMI and requests from borrowers to terminate PMI. You know, in service we won't go into all the policies and procedures. You should have to do that and make sure you're covering it. But it doesn't mean that we can just like throw our hands in the air and say we can charge PMI forever, we don't need to worry about it. That's absolutely not true and we shouldn't take our eye off the ball when it comes to PMI and all kinds of other things. Right, but no, completely agree with you that we still need to pay attention to what we're doing.

Speaker 4:

Look, if there's one thing that's certain in our industry, it's change, and we're going through some rapid changes right now. But I think they're sort of consistent with other things we're seeing come out of this administration. You know saying that we're going to rescind all this guidance related to UWEP. Is you look at the through line to? Also, we just had the updates to the supervisory priorities come out from the Bureau and if you read through those now, it's a long list. It's three pages long. They really say they're going to focus on actual harm to consumers. Well, I would say failure to terminate PMI and continuing to charge a consumer when they shouldn't be charged PMI anymore would be actual harm to a consumer. So it doesn't mean that the Bureau doesn't care about things. It just means they're taking a different approach.

Speaker 2:

So so let me ask you a question. You know I was talking to a neighbor and they are being serviced by your friendly next door neighbor, um, you knowdoor neighbor, mr Somebody, your friendly next-door neighbor. And your friendly next-door neighbor has this service where it I don't know, I can't remember what service it's tied to, but it shows a value service it's tied to, but it shows a value, right? Whether it's a Zillow like a Zestimate, or One of the algorithm ones that doesn't estimate a value of your property.

Speaker 4:

Yeah, yeah, yeah.

Speaker 2:

Yeah, but based off that estimate, my neighbor's saying, well, I'm now at a 67% LTV, right, but I'm still being charged PMI. And so my neighbor, knowing that I'm still in the mortgage industry, asked me isn't this supposed to drop off? I'm like, well, you probably should call right, yeah. So let me ask you now. Now, based off of this information, doesn't your friendly neighborhood subservicer have enough information? Based off their system, shouldn't they have automatically done something?

Speaker 4:

unfortunately, automatic termination is not based on actual value or estimated values from AVMs or you know, I think even my is it my? Where my deposit accounts are? I think I have an estimated value like tied in there it's not even my servicer Like I can tie in my home and I get value. You can get values all over the place but your automatic termination point is going to be based on the loan that was originated. So it's going to be based on the value at the time that loan was originated and automatic termination gets calculated based on LTV from the original loan. So let's say you were at 90% right. So let's say you were at 90% right and it's going to be either based on your purchase price or your appraised value. So if it was a refinance at 90% right, it's going to be your appraised value at the time the loan was bridging and that's how they're going to amortize that out. You're going to have automatic termination at the time that your loan is scheduled to be.

Speaker 4:

At that point the borrower requested termination is different. Um, I don't have it as well memorized, unfortunately, as automatic termination provisions, but that's the whole. Give them a call situation. What are your procedures If I say, oh, I'm below 70% now, like, how does the servicer handle that? But on an automatic termination, unfortunately, um, your Zillows and your gosh. There's a hundred of them out there, right, redfin and everywhere else.

Speaker 4:

Those aren't going to help you with automatic termination, unfortunately.

Speaker 2:

Well, I mean, but so it's a good question. No matter what, there's probably enough data out there for at least a prompt that person to make the phone call though, no matter what, yeah, okay, see, that's good to know, though, yeah okay, there's I.

Speaker 4:

I mean, I tell people that it's, it's true. It's as true when you're not in a delinquency risk situation as when you're in a delinquency risk. We tell you know. We tell folks all the time like if you're in a delinquency risk situation as when you're in a delinquency risk, we tell you know. We tell folks all the time like, if you're in a delinquency risk situation, like communication with your servicer up front is the most important. We tell our servicers, like make sure you're communicating with your customer and your member, especially if they're, you know, in a situation, a delinquency risk situation. But I personally think, like, even when you're current, if you have questions about your loan, like, pick up the phone and call them. They should talk to you.

Speaker 2:

So I'm gonna go down a rabbit hole if I can, yeah, but isn't putting that value on the website after you log in and saying this is what your property is worth, right? Here's your loan balance. Here's what your property is worth. Here's your total equity. Isn't that a little deceptive?

Speaker 4:

I'm going to give you the lawyer answer, which is. It depends.

Speaker 2:

I love it. I love it.

Speaker 4:

I would say it depends how it's presented on the website. Right Like your contract on your loan is one thing. So let's say you have PMI. Right Like that's all going to be governed by that contract. Servicers use estimated values and estimated equity for all kinds of reasons, not the least of which is marketing potential. If they're also a lender right Potential, refi or equity loan or that kind of stuff, it's the marketing tool as well.

Speaker 4:

But as long as disclosures are conspicuous and you know, not misleading, and you're making all your disclosures um, I would say not necessarily deceptive.

Speaker 2:

Okay, hey, you have to ask.

Speaker 4:

It depends. You could definitely create a website that's very deceptive. You could hide the ball on people and do all kinds of things, but I know none of our credit union members would do anything like that. Of course not.

Speaker 2:

No, no, the credit unions. We only care about the people, that's right. That's right, all right. So, so, obviously, that that's PMI and that's how it ties back to, you know, obviously, udap. And you know another thing that that was recently withdrawn was the, the, the charging of unauthorized and unreasonable amounts of fees. Right, so this one is interesting because does this open the door for you to be able to charge the overdraft fee for anything?

Speaker 4:

That's a good question. So yeah, it was part of the same guidance that the charging, overcharging or charging them unauthorized fees was considered a UDOT violation. So there's no official guidance on it anymore. But see, it's the compliance person. But could you still get sideways by charging um an unauthorized fee or charging an overdraft fee or the one I think of? Um that was really a hot topic. Um under the biden administration was um the pay-by-phone fees for the payoffs.

Speaker 4:

For payoffs right well, charging a fee for a payoff that was payoff, that was a big no-no. But also it was the pay by phone. So let's say you're one day away from a late fee for your mortgage. There were servicers that were charging a fee to call and pay with their bank account on the telephone instead of mailing in a check or paying online. Instead of mailing in a check or paying online.

Speaker 2:

So it was these pay-by-phone fees which I mean I don't.

Speaker 4:

I didn't really have most of the servicers I know were passing through the charge that they were being charged by the service to be able to accept and process those pay-by-phone fees or pay-by-phone payments. And so, as long as you I would say there's potential that those fees could be allowed, as long as they are clearly disclosed, they're not overcharged, they're not a surprise, they're not. You know it goes back to disclosure requirements and actually, in the circling back to the enforcement priority list that was put out by the Bureau, they said that disclosure statutes are their best and biggest tool. So it's all about we're back to basics, right, make sure you disclose things to your, your consumers, make sure you're clear, make sure you're not you know no surprise fees. I would say, like, make sure everybody knows, um, what they're getting into, but also consider that like we may still see activity from state attorneys general out there and state level regulations. So I think it's just it comes down to making sure that you are clear, transparent with your consumer and just doing the right thing.

Speaker 2:

Okay, all right. So you said that the charging for a payoff is a big no-no. Now, this was something that came up last year. Was that part of the guidance that was withdrawn, or is it still out there, like you can't charge for a payoff?

Speaker 4:

That is a really good question, and I cannot remember.

Speaker 2:

Oh, I threw you a curveball, didn't you got me, peter, because I mean that I feel like that was like towards august, right, and that was a proposed rule that chobra was was really considering about right. I can't recall if that actually went through, though.

Speaker 4:

Or if it was one of the ones that they're pulling back under the Congressional Review Act. I can't remember either. There's been so much going on.

Speaker 2:

It is truly hard for all of us to keep track of all of the different things that are happening, but mean he did group that into that, that udap fee, though he did chopra, that is, did say that that was a, you know, unfair and deceptive fee for you to be charging um. So it'll be interesting to know whether or not that was included in that. So next thing, and the last thing that we want to figure out is all of the loss mitigation rules that were rolled back. So if you could, I mean, for the sake of time, what were some of the loss mitigation rules that were clawed back as part of the, you know, the, the, really the UDAP things that we really should focus on?

Speaker 4:

Well, we saw some agency action where some of the um last night guidance was that the end dates were pulled back to September. Um, I really think the big one for for the industry as a whole. Those weren't really cataclysmic. They were, you know, like COVID stuff Instead of being extended out into 2026, we pulled things back to September of this year. But there was the proposed servicing rule amendments that were hanging out there. If you remember, those came out about a year ago. Actually, frankly, the intent that was given for these amendments was we learned a lot of things about streamlining loss mitigation during COVID and the streamlining loss mitigation is good. I agree with that. The whole industry agrees. Like we learned a lot about streamlining last minute and that it works and it's not just good for servicers and the industry but it's good for consumers. But then they put out this proposed rule.

Speaker 4:

That was my, my personal opinion, atrocious. Atrocious it was. There were just too many operational issues presented. There were um too many gaps in how things would function. I mean essentially the way the rule was written. You could a savvy consumer, intentionally trying to do so could create a loop of forbearance that just went on and on and on. It just wasn't well written and a lot of really great comments were given back to the Bureau during the comment period about yes, yes, we want to streamline loss met, just not like that. Can we fix some things? Can we do this better? And I was really hopeful that we would get a final rule that was good for consumers, good for industry.

Speaker 4:

Streamline last minute the industry wants this. This isn't something we don't like, the industry doesn't want. We want it desperately. But that's just, it's on, it's out there. So there's no final rule. We don't have anything and I haven't heard any rumors that they're actually going to do a final rule. But that is one I would love to see the Bureau say okay, industry, you're right, the way we did that in 2024 was not great for anybody. Let's amend our RegEx servicing rules and create a streamlined last minute process that works for consumers and the industry. From the lessons learned from COVID. That's the big one I want to see happen. Don't hold down hope.

Speaker 2:

Hold down hope. It's interesting, right, I mean. The big question is, though, it's like I mean, a lot's happening right, and you know, recently you know a gentleman I forgot his last name, but I know his first name is Eli from Tim Scott's office just went over to CPB, and obviously you have Collaborator over there. So it's kind of interesting to see. You know how they are, you know reshaping the CPB, and you kind of wonder what direction they're taking this right, what they're taking this right, what they're putting. Some people in there like obviously collaborate, and you have people from this gentleman from tim scott's office, but again, it's a skeleton crew. Now it is, but but are they actually going to start putting out your true guidance? Or is this still more of assessing and evaluating, to the point where, all right, let's just continue to clean up the mess that we have, right? I think we still need clarification on a lot of things.

Speaker 4:

And I do too. I mean, they pulled back 67 guidance, I think going back to 2013.

Speaker 4:

So it's like, okay, we stripped away all of that, some of which you know industry's happy about, some of which they're not. Like it's a mixed bag of things that were pulled back and, you're right, it's a skeleton crew. They're also immersed in a lot of litigation around sort of the way things have gone down in the last several months. Um, and I'm I'm really curious to see sort of what the go forward approaches. I feel like are they done, doing the housekeeping they want to do? I don't, I have no idea. I wish I did.

Speaker 4:

I'll get my crystal ball for all of us and I'll just start making predictions, um, but I I am cautiously optimistic that when things settle a little bit, that maybe we'll start to get some guidance again. Um, I'm holding out hope, okay.

Speaker 2:

Okay, all right. Well, mandy, we need to start transitioning to the second segment, and thank you very much for all of the important information. Before we do, though, again, I always, like I said, I always end with the same last question. The last question is what keeps you going? I think it's a good balance to the first question is what keeps you going? I think I think it's a good balance to the first question. We found out who you were in that first question, and the second question is that. Well, the last question is when you? What keeps you going? What keeps you motivated? What keeps you driving forward day in, day out? So there you go. What? What keeps you going?

Speaker 4:

I think there. I think there's a dual answer to that. Um, my kids keep me going. For sure, they're definitely a big part of my why. Um, but honestly, it's every the other piece, like on the professional side of things, what keeps me going is I have been eternally blessed with all the wonderful people that I get to work with, not just at my own company, at ACEs. I am lucky in that way. I apologize for the dog barking, no, it's fine.

Speaker 4:

But also all the people outside of my company that I get to work with. It includes you and Krista and Justin and everybody Acuma, but you know the folks that I know from previous companies.

Speaker 4:

I still talk to folks at my old LOS and I get to continue to have those relationships and the fact that we in this in the mortgage industry, we are really lucky. In this in the mortgage industry, we are really lucky. We have a great group of people and we have amazing connections to each other and we can really help each other when we when we want to, and I think I've been lucky enough to work with people that want to help each other and not just help you know their little company, but I've been and and being part of the credit union space is a big part of that. It's sort of that same, you know, sense of community and that we're all in this together and we're all trying to get to the same place.

Speaker 2:

Um, but it's just great people no, I love it, love it, love it, love it. All right, it's time for us to transition to the second segment of our podcast. Now, just like every other compliance episode, we're going to do the most requested, fan favorite series of dad jokes. So, prior to the recording, I asked you to come prepared with two or three dad jokes, and, of course, we're always just going to do two dad jokes. Here's what we're going to do I'm going to have you do your two dad jokes and, of course, we're always just going to do two dad jokes. Here's what we're going to do I'm going to have you do your two dad jokes, justin's going to do his two dad jokes and I will wrap up with my two dad jokes. So, mandy, whenever you are ready, fire away with your two dad jokes.

Speaker 4:

All right, peter. When does a joke become a dad joke?

Speaker 2:

When.

Speaker 4:

When, when the punchline becomes apparent.

Speaker 2:

Good one.

Speaker 4:

That's my new favorite one. I like that one. All right, I got another one. How did?

Speaker 5:

the barber win the race. What did he do? Cut someone.

Speaker 2:

Cut someone off. Cut someone off. He knew a shortcut. He knew a shortcut. Ah, shortcut, there we go. That's right, there you go.

Speaker 5:

Alright, excellent, alright, justin alright, I hired a handyman and gave him a to do list. When I got home, only items 1, 3, and 5 got done, turns out. He only does odd jobs.

Speaker 4:

I like that one.

Speaker 5:

That was a good one. And then, why did the knight surrender once all his limbs were cut off? Wait one more time. Why did the knight surrender once all his limbs were cut off? I thought you said once all his loans were cut off? Wait one more time. Why did the knight surrender once all his limbs were cut off?

Speaker 2:

I thought you said once all his loans were cut off. I was like is this a mortgage joke?

Speaker 4:

A mortgage, dad joke.

Speaker 5:

We have had those, a lot of them, a lot of them.

Speaker 4:

Oh, I need to find some.

Speaker 5:

Why did the knight surrender once all his limbs were cut off? Why, I don't know, because he was unarmed and defeated.

Speaker 4:

That's a good one.

Speaker 2:

Alright, my turn.

Speaker 4:

Alright, Peter, you're up.

Speaker 2:

How do you make an egg roll? You push it. How do you make an egg roll?

Speaker 5:

You push it?

Speaker 2:

Why can't you hear Pterodactyl going to the bathroom?

Speaker 5:

Oh, come on. Do you really want to go with that one?

Speaker 2:

The P is silent.

Speaker 5:

Still a good one though.

Speaker 4:

It was a good one, only by a good one, though. It was a good one, oldie but a goodie, yep, all right.

Speaker 2:

Well, that wraps up this episode of Dad Jokes Mandy, thank you very much for everything that you do for our industry and being a great guest and, of course, looking forward to seeing you at Annual. We have a great session focused on fair lending that I'm really looking forward to having you be a part of, so thank you for actually your you volunteering as tribute for that one.

Speaker 4:

I cannot wait. Hey, y'all are coming to my hometown, so I'll see you in Denver.

Speaker 2:

That's right. That's right. Thank you very much, and Justin, thank you, Of course. It was my pleasure, Of course. And to close out, thank you again to Consolidated Analytics for sponsoring today's episode and to all of you. We know your time is valuable. Thank you for tuning in to the latest episode of Acuma's On Point podcast. We hope you enjoyed it. Until next time. Be well, my friends.

Speaker 1:

We hope you enjoyed it. Until next time, be well, my friends. Thanks for listening. We'll see you next time at the Acuma On Point podcast, if not already. Be sure to subscribe and give us a five-star rating For more great episodes and information. Be sure to visit us online at acumaorg and to get the latest updates, head over to our LinkedIn page.