Yep. And in the real world when a borrower has the choice between an $800 AMC fee or WAIVER after their loan officer tweaked/submitted the file multiple times, what do you think they will choose?
Here's a recent LinkedIn discussion:
**Name redacted for privacy--Boots on the ground appraiser***: have the systems been fixed to prevent loan officers from resubmitting multiple times to trigger a waiver?
During the refinance boom, I knew a loan officer who would submit the same file up to a dozen times — adjusting things like gift letters (to show larger borrower reserves) or the borrower’s estimated value — until a waiver appeared. He said it worked about 30–40% of the time back then.
Fannie Mae’s Selling Guide even flags “an unusually high number of submissions [that] may be the result of data manipulation,” so it seems the issue was recognized. Have those triggers or other safeguards been strengthened to catch this kind of resubmission-based gaming across the automated underwriting systems?
***GSE Guy*** I can't comment on our gaming controls, but gaming is not a common cause of the issue that XXXXX experienced. Keep in mind that lenders need flexibility to change loan parameters because their understanding of the borrower's financial position evolves as underwriting proceeds, so DU must accommodate changes in loan terms. It reassesses the loan application after every material change. This cuts both ways, offering value acceptance when loan parameters shift to reduce collateral risk (say, when the lender's estimate is decreased) but also withdrawing value acceptance (requiring the lender to obtain an appraisal) when the loan application becomes more risky (such as a reduced down payment or more cash out). This ensures value acceptance can only be executed when the loan parameters fall within our established risk tolerance. For the appraiser, this leads to the occasional cancelation but also results in some new appraisal orders for loan applications that lost value acceptance. The bottom line is that this flexibility is a necessary feature of underwriting and, while a cancellation is not pleasant, in general the cancellations are offset by new orders.