Staff shortages, office closings, and high volumes created ongoing disruption for the mortgage industry in 2021.

And, based on MetaSource’s annual analysis of third-party QA reviews, some MERS processes suffered as a result.  

Overall, our analysis showed that the top three areas of MERS compliance challenges fell along familiar themes. We also discovered that while the overall exception rate increased from 11% in 2020 to 19% in 2021, some notable improvements were made.

This report discusses why these improvements occurred, details surrounding what MERS Members struggled with the most, and best practices for overcoming these struggles in the future.

Top MERS QA Audit Findings for 2021

Here are the MERS QA challenges that Members struggled with most in 2021:

The Challenges of Maintaining Detailed, Up-to-Date Policies & Procedures

Ensuring that internal policies are thorough and up-to-date is a perennial struggle for many MERS Members. But it was heightened in 2021 when additional difficulties, including staffing shortages, left some servicers without the MERS support they needed. Many servicers were left to rely on staff members who were unfamiliar with MERS requirements and the level of detail necessary to meet current policy and procedure expectations.

Other servicers fell short of MERS requirements for written policies and procedures as their monthly volumes swelled and, for the first time ever, pushed them over the 1,000-mortgage identification number (MIN) mark. MERS Members over this MIN mark as of March 31 are required to obtain a third-party review, which includes a thorough review of MERS Members’ operational policies and procedures in preparation for the MERS eAnnual report due each year by December 31. Those new to this MIN volume level last year were left subject to monthly reconciliation requirements and third-party reviews for the first time. Similar to those experiencing staffing shortages, these servicers were unfamiliar with the requirements and failed to provide adequate written internal policies and procedures.

This unfamiliarity undoubtedly led to an increase in policy and procedure-related challenges and a rise in the overall exception rate. “About 90% of the Members I reviewed last year did not have detailed procedures,” said Rachel Pylant, MetaSource Director of MERS Services.

The Areas that Showed Improvement

While more Members struggled to meet written internal policy and procedure requirements last year, there were signs of improvement in other areas.

Download the full report to learn what these areas of improvement were, the main reasons for the improvements, and the best practices for ensuring MERS compliance in 2022.

In a year in which record mortgage volumes collided with staffing shortages and ongoing economic volatility, mortgage quality control difficulties remained mostly the same as years prior. However, there were some new challenges in 2021.

This findings report digs into those new challenges, provides MetaSource’s top 15 findings for the year, and offers advice on how you can avoid findings in 2022.

Top QC Findings for 2021

Here is the complete list of our top 15 mortgage QC findings for 2021, including all loan types and both regulatory and agency findings:

#1 Finding: Still a Continuous Trend

The finding “closing disclosure tolerance defects” tops the list, as it has in five of the last six years. Even so, there were signs of a worsening trend in 2021, claiming over 15% of all MetaSource significant findings, compared to around 13% in 2020.

Why is this the case?

MetaSource Senior Director of Mortgage Services, Brady Meadows provided some insight: “As best we can tell, this is because lenders were so busy trying to keep up in 2021, that documentation took a back seat.” Meadows explained that many lenders did not fail to adhere to tolerance regulations, but rather failed to provide MetaSource with the required documentation.

Documentation issues were also prevalent in MetaSource’s analysis of top findings by Fannie Mae category. Loan package documentation was by far the largest Fannie Mae category of defects, accounting for more than 60% of the findings.

Income Documentation: A Source of Difficulty for Lenders in 2021

There was a steep increase in the number of income documentation aged defects, with 43% more significant findings related to documenting borrower incomes than in the previous year – pushing income documentation defects to 3rd in ranking in 2021, up from 10th on our 2020 list.

Download the full report to learn why this increase occurred, what other findings moved up the list in 2021, and how you can minimize findings in 2022.