Pre-close QC
Every rule a loan has to pass before it funds, and how Sei checks it
A pre-close review is five checklists run against one loan file. Most of what it catches is not a missing document. It is two documents that disagree, or one that is a week too old.
Sei’s Pre-Close QC Agent runs the agency rule set for the loan’s program — Fannie Mae and Freddie Mac, FHA Handbook 4000.1, VA Pamphlet 26-7 — and your investor overlays on every file before it funds. Each rule ends in a verdict, the reason, the page it was read from and the line quoted off that page. This guide is that rule set written out: what is checked for each program, where the programs disagree, and how the agent gets from a file of several hundred pages to a decision a QC lead can sign.
Identify issues, catch fraud and reduce your repurchase risk before closing
Five checklists, one file
The same five checklists run on every loan. The program decides which rules inside them apply, and the loan’s own facts decide the rest — a gift-funds rule on a file with no gift is marked not applicable, with the reason, rather than failed or silently skipped.
- 01
Pre-close
Eligibility and the closing package: whether this loan, on these terms, with these documents, can close.
- Every borrower signed the initial application, and nobody signed it who will not be on the Note
- The purchase contract is complete, signed by the buyers on the 1003, and agrees with the loan on price, credits and parties
- Title names the lender with its successors-and-assigns clause, vests in the borrower on a refinance, and puts the new loan in the right lien position
- Hazard and flood policies cover the subject address, the mortgagee clause and the closing date
- 02
Underwriting
The decision behind the approval: the AUS run, every condition on it, and the credit file it was scored on.
- The latest AUS submission matches the final 1003, the 1008 and the Closing Disclosure
- The credit report reference number matches the AUS run it was scored on
- Every AUS condition is cleared by a document in the file, named
- Waiting periods after a bankruptcy, foreclosure, short sale or deed-in-lieu are met from the right date
- 03
Income
Each qualifying figure, recalculated from source and documented to the rules for its own income type.
- Two years of history for base, overtime, bonus and commission, and the averaging method the guide sets
- Self-employed income from the returns and transcripts, with year-over-year decline tested
- Rental income from the Schedule E or the lease and market rent, at the guide’s vacancy factor
- Non-taxable income grossed up only as far as the program allows
- 04
Assets
Twenty-one sources of funds, each with its own documentation rules, tested for ownership, age, seasoning and sufficiency.
- Bank, brokerage and retirement statements: account holder, every page, statement age and period covered
- Gifts, gifts of equity, grants, down payment assistance and employer assistance: donor eligibility and transfer evidence
- Borrowed funds, bridge loans and the sale of personal or real property: the debt in the ratios, the proceeds evidenced
- Earnest money, large deposits, virtual currency, cash on hand and credit-card rewards, each under its own rule
- 05
Appraisal
The collateral and the report that values it, including the property standards each government program adds.
- The right report for the property type, signed, and submitted through the agency portal with a successful status
- Comparables, adjustments, zoning and highest and best use, as the appraiser supported them
- A report made subject to completion or repairs has the completion certificate behind it
- Condo and PUD project review complete for the review type used
The file, sorted before a rule is read
Before a single rule is read, every page is split into its documents and filed into one of thirteen categories, so a finding points to a named document — not to page 412 of a PDF nobody wants to scroll.
Application
Initial and final 1003, HUD and VA addenda, the 1008, declarations, the compliance events timeline
Credit
Tri-merge report, supplements, refreshes, the fraud and identity report, letters of explanation
Income
Paystubs, W-2s, written and verbal VOEs, tax returns and transcripts, award letters, leases
Assets
Bank, brokerage and retirement statements, gift letters, transfer evidence, VODs
Appraisal
The report and its addenda, photographs, sketch, completion certificate, the agency submission report
Title and legal
Title commitment, closing protection letter, E&O certificate, tax certificate, survey, power of attorney
Property and HOA
Project questionnaire, HOA certification, budget, master policy, CC&Rs
Insurance
Hazard declarations or binder, flood certificate and policy, HO-6, mortgage insurance certificate
Purchase contract
The contract, counter-offers, addenda, amendments and seller disclosures
Disclosures
Loan Estimates, the disclosure timeline, homeownership counseling list, program and state disclosures
Closing
Closing Disclosure, settlement statement, closing instructions, payoff statements, the Note when signed
AUS and conditions
DU or LPA findings for every run, the approval, the condition list and what cleared each one
Agency forms
FHA case assignment and CAIVRS, the VA COE, Notice of Value, Loan Analysis and 26-8937
One question, three programs, three answers
A reviewer who moves between programs carries the wrong number across more often than they miss a rule. These are the questions every pre-close review asks, with the answer each agency guide gives. Overlays tighten them; none of these is an overlay.
The checks, program by program
The full rule set for each program, grouped the way a pre-close checklist is. Each line is something the agent checks against the file and decides, with the page it read it from.
Conventional
Fannie Mae Selling Guide · Freddie Mac Seller/Servicer Guide
Two guides that agree on most things and disagree on enough to matter. The agent reads which agency the loan is going to from the findings and applies that agency’s rule where they differ — gift-of-equity donors, IDA matching ratios, reward points, cash back on a refinance.
Paper only this program adds
- DU or LPA findings, every run
- Form 1008 transmittal
- Mortgage insurance certificate above 80% LTV
- Agency appraisal submission report (UCDP SSR)
Credit and liabilities9
- The credit report is no more than 120 days old on the note date, measured from its pull date — not the print date — and a supplement or refresh resets the clock
- The report’s reference number matches the AUS run the loan was approved on, and names, addresses and SSNs match the 1003
- Mortgage history: any 60-, 90-, 120- or 150-day delinquency in the 12 months before application is tested against the findings
- Waiting periods run from the completion date of the event as the credit report or the borrower’s documents show it
- Debts excluded as paid by someone else carry 12 months of that party’s payments; a debt assigned by court order carries the order
- Lease payments are in the ratios however few months remain; 30-day accounts are covered by verified funds
- A HELOC on the subject is documented for its balance, its limit and whether it stays open
- Mortgages on other real estate are on the credit report, or documented with taxes, insurance and dues in the ratios
- The OFAC check is clear
Assets and funds to close13
- A borrower is the named holder of every account used to qualify, and every statement is complete and legible
- An online printout or transaction history carries the institution, the account, the borrower’s name, the date and the URL it was printed from
- Statement age and coverage per the guide and the findings; brokerage and retirement accounts on the latest statement whatever the transaction
- Earnest money: if it left the account before the statement end date the balance already reflects it; if after, the cleared check or wire is in the file
- The gift letter names the amount, the donor’s name, address, phone and relationship, and says no repayment is expected; the transfer is evidenced by check and deposit slip, withdrawal and deposit, wire, or the settlement statement
- Gift of equity: eligible donor, principal residence or second home only, on the settlement statement, and never counted as reserves
- Minimum borrower contribution from the borrower’s own funds where the guide requires one
- Personal unsecured loans — signature loans, card cash advances, overdraft lines — are not a source of funds
- Funds borrowed against an asset: the payment is in the ratios, and the loan is subtracted from the asset if that asset is also counted
- Sale of a personal asset: proof of ownership, a bill of sale, a buyer who is not a party to the transaction, and an independent value when the proceeds are large against income
- Virtual currency counts only once converted to dollars and held in a U.S. institution, with ownership and the liquidation shown
- Grants, IDAs, sweat equity, employer assistance, trade equity and an agent-borrower’s earned commission each carry the agency’s own eligibility test
- Funds are sufficient for the down payment, closing costs, any debt paid to qualify, and the reserves the findings require
Solar panels and PACE5
- Owned outright: part of the property, valued by the appraiser
- Financed with a UCC fixture filing in the land records: the debt in the DTI and in the CLTV as other debt secured by the property
- Financed but not on title: the debt in the DTI, and the panels excluded from the appraised value and the LTV
- Leased or under a power purchase agreement: the agreement is in the file, the payment is in the DTI unless the agreement is a fixed-production structure the guide exempts, the home keeps an alternate power source, and the equipment owner is responsible for damage and removal
- A PACE obligation is paid off or subordinated before closing
Purchase contract3
- Fully executed, every page and every addendum the contract refers to, with price, seller credits and interested-party contributions that agree with the Closing Disclosure
- The seller on the contract is the vested owner on title; an entity, trust, relocation company or agent under a power of attorney is checked for authority instead
- Interested-party contributions within the limit for the occupancy and CLTV
Title, taxes and lien position8
- The lender’s legal name with its ISAOA/ATIMA clause on the commitment and the closing protection letter
- On a refinance, title vests in the borrower
- Every lien and judgment on the commitment is paid at closing, subordinated or cleared, and the new loan will be in first position
- A subordination agreement for every lien staying open, at an amount that covers the new loan
- The settlement agent’s E&O certificate is in the file and in force
- The tax certificate’s address, county, owner and parcel number agree with title and the appraisal, and the monthly tax figure in the payment is calculated from it correctly
- Title coverage at least equal to the loan amount, effective at closing, with the endorsements the loan needs
- A survey where state practice puts one in the file
Insurance4
- A hazard policy or binder for the subject address, effective at disbursement on a purchase and at closing on a refinance, and not about to lapse
- Coverage at least the lesser of 100% of replacement cost and the unpaid principal balance, as long as that is at least 80% of replacement cost
- A flood determination for the subject address; in a zone beginning with A or V, a flood policy with the right mortgagee, insured, address, term, premium and zone
- An HO-6 walls-in policy when the condo or attached PUD master policy does not cover the unit interior
Disclosures and program terms5
- The homeownership counseling list, generated for the borrower’s zip code, sent within three business days of application
- A net tangible benefit worksheet where state law requires one
- Temporary buydowns within the guide’s terms; HomeReady buydowns on purchases, fixed-rate or seven- and ten-year ARMs only
- Limited cash-out and cash-out refinances inside their own eligibility rules
- The borrower certification and authorization signed by every borrower
Underwriting5
- The last AUS submission is the one the loan closes on, and its data matches the LOS, the 1003, the 1008 and the Closing Disclosure
- Every condition on the findings is cleared by a document in the file — named, not assumed
- Mortgage insurance coverage is in the file above 80% LTV
- A non-permanent resident’s documentation is current, front and back
- Occupancy is credible: a second principal residence, a long commute or a landlord insurance policy is a question, not a pass
Appraisal and project7
- The right report for the property — Form 1004, 1073, 1025 or 2055, or the UAD 3.6 URAR that replaces them — signed by the appraiser and any supervisor
- The agency submission report shows a successful status, submitted after the final revision of the report
- A report made subject to completion or repairs has the 1004D or completion report, with photographs
- Comparables closed within 12 months, adjustments within the guide’s net and gross limits, and the subject bracketed by the comparables
- Predominant price and age stated as whole numbers; zoning legal or legal non-conforming; present use the highest and best use
- A private road shared by several properties has a maintenance agreement; multiple parcels and accessory units meet their own rules
- Condo and attached PUD: the project review documents for the review type used, investor concentration and a budget that funds reserves
FHA
HUD Handbook 4000.1
The longest checklist of the four, because the Handbook is prescriptive where the GSE guides leave room. The FHA case file adds its own paper, a scorecard that has to be re-run when facts move, and property standards the appraiser certifies to.
Paper only this program adds
- FHA case number assignment and case query
- CAIVRS authorization for every borrower
- HUD-92900-A, initial and final
- Amendatory clause and real estate certification
- Refinance authorization on an FHA-to-FHA refinance
- FHA condominium ID or single-unit approval
Application and case assignment8
- Every borrower signed and dated the initial 1003 and pages 1 and 2 of the initial HUD-92900-A; nobody signed who will not be on the Note
- The final HUD-92900-A carries the underwriter’s signature and an approval date on or after the last AUS run
- The 1003 shows the loan originator’s name, NMLS ID, phone and signature
- A power of attorney is used only where the Handbook allows it — a service member overseas or on an unaccompanied tour, or an incapacitated borrower under a durable POA
- The case number, assignment date, ADP code, term, amortization, program, property type, condo or PUD indicator and address on the case assignment agree with the file
- The case query shows the case active, not cancelled, and the borrower SSN validation passed
- CAIVRS returns an authorization number beginning with A for every borrower
- One FHA-insured principal residence at a time, unless the borrower meets an exception: relocation, a larger family, vacating a jointly owned home, or a non-occupying co-borrower
Income12
- Two years of employment and income history verified directly, from paystubs and W-2s or a written VOE
- Only legally derived income, reported on the tax returns where it has to be
- Overtime, bonus, tips, commission and automobile allowance with two years of history — or at least one with justification — averaged as the Handbook sets; commission and auto allowance net of Form 2106 expenses
- Employment gaps longer than six months, and over three employers in 12 months, explained and documented
- Temporary leave: pre-leave income if the borrower returns by the first payment; current income plus surplus reserves if after
- Self-employment of two years, or one to two with prior work in the same line; a decline of more than 20% downgrades the loan to a manual underwrite
- A year-to-date profit-and-loss and balance sheet when more than a quarter has passed since the last tax year
- Non-taxable income grossed up by no more than the greater of 15% or the borrower’s tax rate
- Rental income from the subject only on a 2–4 unit, or a one-unit with an ADU — the ADU’s income capped at 30% of the total where there is no rental history
- Boarder income with two years of history on the tax returns, at the lesser of the average and the current lease
- Expected income guaranteed to start within 60 days of closing, with reserves to bridge it, and never from a family-owned business
- A borrower employed by a family business is shown not to be an owner
Credit10
- A tri-merge report for every borrower on the Note, no more than 120 days old, with the mortgagee and the reporting agency named
- A credit freeze or fraud alert addressed; every address on the report checked for undisclosed real estate or an occupancy question
- Community property states: a credit report for the non-borrowing spouse, their debts in the ratios unless state law excludes them — with the statute noted in the file — and their judgments resolved
- Disputed derogatory accounts totalling $1,000 or more, excluding medical and identity theft, downgrade the loan to a manual underwrite
- Judgments paid, or three months of on-time payments under an agreement that keeps the FHA loan senior — payments may not be prepaid to get there
- Delinquent federal non-tax debt makes the borrower ineligible until resolved; a CAIVRS hit is verified with the creditor agency before it is relied on
- Authorized-user accounts are in the ratios unless the primary holder’s 12 months of payments are documented
- Closed-end debt paying off within 10 months is excluded only if those payments total no more than 5% of gross monthly income
- Deferred obligations, installment and revolving payments, child support and alimony, contingent liabilities and private savings clubs, each counted the way the Handbook says
- Mortgage history in the 12 months before case assignment tested against the downgrade thresholds; a modification needs six payments under its terms, and a forbearance plan ends at or before closing
Refinances6
- Cash-out: owner-occupied principal residence only, owned and occupied for the 12 months before case assignment, six months of payments, every payment made in the month due, 80% of the adjusted value, and no income from a non-occupying co-borrower
- Rate-and-term: owner-occupied principal or HUD-approved secondary residence, 97.75% LTV and CLTV for a principal residence occupied 12 months, cash back no more than $500
- Simple refinance: FHA to FHA, 97.75% on a principal residence and 85% on a HUD-approved secondary residence
- Payoff statements for every mortgage being paid, with the interest period checked
- Short payoffs, buying out a title-holder’s equity and paying off a recorded land contract, each under its own rule
- At least one borrower held title before case assignment
Purchase contract8
- The complete final contract, with every addendum that changes the terms or the underwriting decision; standard advisories are not required
- The buyer named on the 1003 signs the contract, and the seller is the owner of record
- The amendatory clause and real estate certification, signed by buyer, seller and agent, when the value statement was not issued before the contract
- The Informed Consumer Choice disclosure and HUD’s required homebuyer notices
- Interested-party contributions within 6% of the sales price, and inducements to purchase — furniture, vehicles, excess contributions — deducted from the mortgage amount
- Identity-of-interest transactions held to 85% LTV unless an exception applies: a family member, a builder’s employee, a corporate transfer or a tenant purchase
- A resale within 90 days of the seller’s acquisition is ineligible
- Mixed-use property at least 51% residential; a property that will keep a PACE obligation is ineligible
Assets and funds to close10
- The borrower’s name on each statement, within 120 days of the note date, every page present, and online statements with the URL and the institution
- Recurring payments in the statement history that are not on the credit report, explained or added to the ratios
- Individual deposits above 50% of monthly effective income documented
- Gifts and gifts of equity from eligible donors; the Minimum Required Investment of 3.5% from an acceptable source
- The upfront MIP financed in full or paid in full in cash, and personal property bought separately excluded from the price
- Reserves of three months’ PITI on a 3–4 unit, and two months where ADU rental income is used
- On a 3–4 unit, PITI divided by net self-sufficiency rental income does not exceed 100%
- Cash on hand explained and reasonable for the time it was saved; sale of personal property at the lesser of the estimated value and the sale price
- Proceeds from a sale of real estate shown on the executed Closing Disclosure, from an arm’s-length sale
- Borrowed funds only from an independent third party, never an interested party; an SBA disaster loan on the subject subordinated
Title, insurance and the payment5
- A complete preliminary title report with the legal description and a 24-month chain of title
- Lender name with ISAOA on title and the closing protection letter; exceptions addressed; liens cleared; first-lien position
- Hazard and flood policies with the mortgagee clause, borrower name, loan number and address, effective at closing, with the flood zone matching the certificate
- The monthly hazard premium and the monthly MIP in the payment match the policy and the Handbook’s premium tables for the loan amount, LTV and term
- Condos and attached PUDs: the master policy, an HO-6 where the master does not cover the interior, and fidelity coverage on the projects that need it
Condominium projects5
- The project is on HUD’s approved list and its FHA condo ID is on the case assignment — or the unit qualifies for single-unit approval
- Single-unit approval: occupancy, delinquency and concentration within the Handbook’s limits — no more than 15% of units in arrears, and no single owner above 10% of a project of 20 or more units
- Commercial space no more than 35% of floor area, and a live/work unit no more than 49% commercial
- Control transferred to the owners, recorded documents in place, and the master, liability and fidelity coverage the project size requires
- Projects in a special flood hazard area, leasehold projects and site condominiums each under their own rule
Rescoring, fraud and the decision5
- The loan is rescored when any data element changes, and must be when liabilities rise by more than $100 a month, reserves fall more than 10% or income falls more than 5% below what was scored
- Every party — borrowers, seller, appraiser and appraisal company, employer, loan officer, agents — checked against HUD’s Limited Denial of Participation list and the federal exclusion list
- No unresolved red flags on income, employment, assets, occupancy, SSN, documents or the contract
- Non-occupying co-borrowers held to 75% LTV, or 96.5% where they are family members and the transaction qualifies
- The underwriting decision is supported by the file the loan closes on
Appraisal and property standards7
- The appraisal’s effective date is not before case assignment, and a new appraisal is ordered for each case number
- Neighborhood boundaries defined; zoning marked legal, legal non-conforming, none or illegal
- Homes built before 1978: every surface observed for defective paint
- Utilities on and systems operated, or the report made subject to it; contributing appliances operational
- A transfer by foreclosure to a mortgagee is not evidence of market value
- Proposed and new construction carries its inspections; runway clear zones, termite areas and water tests are handled as the Handbook sets
- The appraiser’s license and the required photographs are in the report
VA
VA Pamphlet 26-7 and VA circulars
VA turns on the veteran: their eligibility, their entitlement, their funding fee and their family’s residual income. A VA review that reads like an FHA review with different forms misses the half of it that has no FHA equivalent.
Paper only this program adds
- Certificate of Eligibility
- Notice of Value
- VA Loan Analysis (26-6393)
- Verification of VA Benefits (26-8937), where the COE calls for it
- Counseling Checklist for Military Homebuyers (26-0592) for active duty
- Determination of eligibility (26-1817) for a surviving spouse
Eligibility and entitlement6
- A valid COE, its name and SSN matching the file, and every condition printed on it satisfied
- Funding-fee status read off the COE — exempt, non-exempt, or a 26-8937 required — and a non-exempt fee calculated for the down payment and first or subsequent use
- The funding fee financed into the loan or paid in cash at closing from the veteran’s own funds
- Basic entitlement of $36,000 on loans of $144,000 or less; above that, enough entitlement for a 25% guaranty where the veteran’s entitlement is reduced
- Prior entitlement on the COE: restored after a sale and payoff, by one-time restoration, or not at all where the property went to an ex-spouse
- A surviving spouse’s eligibility determined on the 26-1817
Borrowers and occupancy6
- The veteran whose entitlement is used is a borrower; joint loans follow VA’s rules on who may join
- The veteran will occupy within 60 days, or within a reasonable time under the certification VA allows — including a spouse or dependent child occupying for a service member
- Term no longer than 30 years and 32 days; the loan purpose is one VA guarantees
- Active duty: the counseling checklist signed, and orders for a change of duty station
- A power of attorney is a specific POA with the content VA requires, with evidence the veteran is alive and well
- Every dependent on the application, with ages, because they drive residual income
Credit9
- The report is within 120 days of the note (180 for new construction), covers all borrowers, and reports two years of residence and employment
- Proof of the full SSN for every borrower, matching the COE and the credit report
- CAIVRS checked for every borrower; delinquent federal debt makes the borrower ineligible until current
- Undisclosed debt: 12 months of history for a mortgage the file did not disclose
- Bankruptcy, foreclosure, short sale and deed-in-lieu waiting periods, and re-established credit after them
- Community property states: the non-borrowing spouse’s debts in the analysis, with judgments and collections weighed
- Deferred student loans, installment and revolving payments, open 30-day accounts and contingent liabilities counted as VA sets; disputed accounts excluded unless reduced to judgment
- The 26-8937 checked for VA debts — overpaid education benefits, for one
- Child-care costs where young dependents are declared, and commuting costs where the commute is unusually long
Residual income and ratios5
- Family size counts every member of the household, including a spouse not on the loan
- The residual income requirement for that family size, the loan amount band and the property’s region
- Residual income calculated the same on the Loan Analysis and the AUS, and the debts on the Loan Analysis matching the AUS
- Above 41% DTI, residual income at least 120% of the requirement, or the exception documented
- Compensating factors written up when credit or residual income is marginal
Purchase contract5
- Every page, counter-offer and addendum; manual corrections initialed by both sides
- The VA escape clause in the contract or signed separately by the veteran and the seller
- Seller concessions within 4% of reasonable value
- A contract amended after the appraisal’s effective date has the appraiser told
- Lead-based paint disclosure on a home built before 1978; the seller on the contract is the owner on title and the appraisal
Assets and reserves6
- Verified assets agree on the final 1003, the AUS and the Loan Analysis, with a statement for every account listed
- Liquid funds cover the veteran’s share of closing costs, prepaids and discount points
- Three months of PITI in reserves for each rental property whose income is used, and six months on a multi-unit principal residence using rental income
- Proceeds of a VA refinance never count as reserves for a rental property
- Gifts transferred and documented, never used for reserves, and never from an interested party
- Recurring withdrawals on the statements that point to an undisclosed debt
Title, insurance and subordinate financing6
- Proposed vesting in the borrowers — a non-borrowing spouse may be added — in fee simple or an approved leasehold
- A 24-month chain of title; Schedule B-I requirements met and Schedule B-II exceptions that do not threaten first-lien position
- Tax certificate owner and parcel number agree with title and the appraisal, and the tax figure in the payment is right
- Hazard coverage effective by closing; in a special flood hazard area, flood coverage of at least the lesser of the loan balance, the insurable value and the $250,000 NFIP maximum, with the zone agreeing on the policy, the certificate and the appraisal
- A condo or attached PUD master policy covering common elements and units
- Any second mortgage subordinate to the VA loan, with no cash back to the veteran from either
Refinances2
- Cash-out: the comparison certification, the veteran’s occupancy certification, the seasoning requirement and the stated use of proceeds
- IRRRL: a comparison of the old and new loans, and fees and costs recouped within 36 months
Appraisal and the Notice of Value5
- The Notice of Value carries the right loan number and address, and its conditions agree with the appraisal
- Only the VA-assigned fee appraiser signs, and the appraisal was ordered after the COE
- Items that fail VA’s minimum property requirements are repaired, not left to an inspection
- Wood-destroying insect reports where required, leased equipment identified, and properties in a declared disaster area re-inspected
- New construction: completion evidence and the builder’s warranty
HELOC and second liens
Investor guidelines · Regulation Z
No agency writes a home-equity guide, so most of the credit rules are the investor’s and the consumer rules are Regulation Z’s. Which of them apply depends on what the loan is — open-end or closed-end, which lien, which documentation program — so that is settled before anything else, because a first-lien rule applied to a second lien is a false finding.
Paper only this program adds
- The current statement on every lien ahead of the new one
- A title or property report suited to the lien position
- The HELOC agreement or the closed-end second Note
Consumer rules3
- Open-end line: the Regulation Z §1026.40 application disclosures and the home-equity brochure, delivered at application
- Closed-end second: the Loan Estimate and Closing Disclosure timing, and the ability-to-repay rule
- The right of rescission where the line or loan is secured by the borrower’s principal dwelling
Collateral and liens3
- CLTV from the current balances of every senior lien; HCLTV with the full line amount, not the amount drawn
- Every senior lien current, and its position confirmed on the title or property report
- Flood insurance where the property is in a special flood hazard area, as for any lien
Capacity2
- The senior payment in the ratios at its actual amount from the statement, with escrowed taxes and insurance counted once
- Income documented to the program the loan was approved under — and rules for documentation that program does not use marked not applicable, with the reason
What makes it pre-close
A pre-close review reads a file that is not finished. Some documents do not exist yet, some dates have to be sourced from somewhere else, and the file carries several versions of the same thing. These are the rules the agent applies so that an unfinished file is not read as a defective one.
Closing-time documents are not defects yet
Some documents only exist once the loan closes — the final title policy, the final verbal VOE, the final Closing Disclosure. When the only gap is one of these, the finding says so and stays open for closing, instead of failing a file for being on schedule.
The note date, before there is a Note
Document ages run to the note date, and before closing there is no Note. The agent tests against the scheduled closing and marks the verdict pending the executed Note — it never borrows a date that merely sits nearby.
The application date, from the file’s own record
The three-business-day clocks run from the application date, so it is taken from the file’s own record of when the application was received — and the finding names where it came from.
The latest of everything
A file holds three AUS runs, two credit pulls and a revised 1008. The agent reads the last AUS submission, the credit report tied to it — or the most recent one before the note date — and the latest 1008, and says which instance each verdict read.
The subject, not the other house
A Closing Disclosure, settlement statement or purchase contract is used only once its property address matches the subject. A borrower selling one home and buying another has two of each in the file, and the wrong one passes every arithmetic check.
Overlays are rules of their own
Investor and lender overlays are separate, named rules layered on the agency base — never edits to it — so a finding says whether it failed the guide or the overlay. Both are version-controlled and dated, so a loan is held to the rules in force for it.
What every review promises
How the engine works is ours to keep. What it promises is yours to test, so each of these is written as something you can check on your own files.
- 01
Every page, read
Scans, phone photos, sideways pages and duplicate copies included. A file is not reviewed on the pages that happened to be legible. The Indexing Agent splits and files the same pages as a desk of its own.
- 02
Only the rules that apply
The program, the transaction and the borrower decide which rules apply. A rule that does not is marked not applicable with the reason, and no rule is skipped because a fact in the file was unclear.
- 03
Missing means missing from the file
A document is reported missing only when it is absent from the whole file — not because it sat on a page nobody looked at, and not because the scan was hard to read.
- 04
Numbers you can re-add
LTV, qualifying score, funds to close, reserves, date windows and waiting periods are calculated, not estimated, and every figure shows its inputs and the page each came from.
- 05
Conditions tied to their evidence
Every condition on the DU or LPA findings is matched to the document in the file that clears it, by name, or reported open.
- 06
A citation on every verdict
Every pass and every fail carries the page and the line quoted from it — checkboxes, signatures and form grids included, not only typed text.
- 07
Nothing cleared unverified
A verdict that contradicts its own reasoning, or a pass with no evidence behind it, is not published as it stands. What cannot be verified reaches a reviewer marked as such, and every finding carries a confidence.
How a verdict is decided
Four verdicts. A rule that applies ends met or not met; “not sure” is not a verdict — it is a named item on a reviewer’s desk.
- YES
Met
The requirement is satisfied on the evidence — or the rule prohibits something and it is absent. An equivalent document counts: the UAD 3.6 URAR satisfies a rule written against Form 1004 or 1073.
- NO
Not met
The rule applies and the evidence contradicts it, or a document the rule requires is absent from the whole file. A missing required document is a defect, not a maybe.
- NA
Not applicable
The rule does not apply to this loan, property or borrower, and the finding says why in a sentence.
- PARTIAL
For a reviewer
Kept for the rule that applies but whose evidence cannot be settled from the file. It lands on a reviewer’s desk as a named exception, never as a pass.
Rules of evidence
- A document being in the file is not the rule being met. The hazard policy being present does not mean its coverage is enough.
- Not applicable and not met are different findings. Missing evidence for a rule that applies is a NO, not an NA.
- Missing is a statement about the whole file, never about the pages one check happened to read.
- Every YES and NO quotes the line it rests on, or says plainly that it rests on an absence.
- Every finding carries a confidence, and a low one goes to a person rather than into the report.
FHA · Credit · The credit report is no more than 120 days old at the note date
- Reason
- Tri-merge pulled 07/14/2026; closing date on the Closing Disclosure 10/02/2026, 80 days. Executed Note not yet in the file — pending final Note date.
- Evidence
- “Date Ordered: 07/14/2026”
- Cited
- Credit report p.1 · Closing Disclosure p.1
Run it on your own files
Send us closed files from your own pipeline — including the ones that came back as an investor finding or a repurchase demand. You will see every rule the agent ran on each, the findings with their pages, what it marked not applicable and why, and where it disagrees with the review your team signed.
- Your overlays loaded beside the agency rules, and named as yours in every finding
- Conventional, FHA, VA and HELOC files in the same run
- Findings in the shape your investor or agency already asks for
The desks that share the file
Pre-close QC is the last desk to read the file before it funds. The others that touch it on the way are part of the same system and read the same loan model, so a finding on one is already context on the next.
For Lenders
Pre-Close QC AgentPre-close quality control on every loan, with agency- and investor-ready audit trails.- Indexing AgentSplits and files every page, so each rule reads the right document.
- Income DeskRecalculates the qualifying income the income checklist tests the file against.
- Conditions ManagerTurns a pre-close NO into a condition and clears it as the evidence lands.
- Fraud AgentTests every document for fabrication behind the “no red flags” rule.
- TRID & Cure ManagementRuns the disclosure clocks and tolerance cures whose outcome QC checks.
Further reading on QC and underwriting
Pre-Funding QC With an AI Agent: The Fannie D1-2 Review, the Defects You Catch Before the Wire, and the Reverifications the Rule Still Wants a Human to Judge
Post-closing QC tells you how many defective loans you already sold. Pre-funding QC is the only review that changes the outcome, because it happens before the money moves. An AI agent can run the full-file pre-funding review at 100 percent of the pipeline instead of a sample, catch the income-calculation error and the data-integrity break before closing, and drive the reverifications the rule requires. What the agent computes, what stays human, and how the defect taxonomy has to be built so the review is defensible.
7 min readMortgage QC at 100% Coverage: What Changes When AI Reviews Every Loan Instead of a 10% Sample
GSE quality control rules were written around sampling because full review was impossible by hand. AI removes that constraint. What a full-population pre-funding and post-close QC program looks like, and where the Fannie and Freddie requirements still bind.
6 min readReading the AUS Findings: Where an AI Underwriting Agent Adds Value, Where SR 11-7 Draws the Line, and Why the Model That Touches Credit Is Governed Differently
The automated underwriting system already returned Approve/Eligible. The work that follows, clearing the findings, reconciling the conditions against the file, and deciding what the AUS could not see, is where cycle time and defects live. Where an AI agent operates on DU and LPA findings, why an agent that influences a credit decision falls under model risk management, and the governance we run so the agent is a documented, tested model and not a black box in the underwriting path.
7 min readThe Large Deposit Question: Verifying Assets With an AI Agent Under Fannie Mae B3-4.2-02, and Where Asset Sourcing Meets the Bank Secrecy Act
Asset verification looks like adding up account balances and is actually a sourcing investigation. The 50 percent large-deposit rule, funds that have to be the borrower's own, gift documentation, and the point where an unexplained deposit stops being an underwriting condition and becomes a source-of-funds question a regulated lender cannot ignore. Where an AI agent reads bank statements, what it flags, and the line between an eligibility problem and an AML problem.
7 min readWhose Money Is It, and Can You Prove It: Verifying Gift Funds and Down-Payment Assistance With an AI Agent Under Fannie B3-4.3-04
A gift toward the down payment is the one place in asset verification where the paper trail and the relationship both have to hold, and where the sourcing question quietly becomes a Bank Secrecy Act question. How we build an agent that documents the donor, the transfer, and the availability of funds, tells a personal gift apart from a gift of equity and a DPA second, and knows the exact point at which it stops verifying and escalates to a human.
6 min readThe Credit Pull Is Not One Event: Undisclosed-Debt Monitoring, the Pre-Closing Refresh, and the Permissible-Purpose Line an AI Agent Cannot Cross
A mortgage credit file is pulled at application and again before the note signs, and the gap between those two pulls is where a borrower opens a car loan the underwriter never saw. An AI agent that watches that gap touches FCRA permissible purpose, the Fannie Mae age-of-documents rule, and the re-underwrite decision. Where the agent monitors, what it is allowed to pull, and why it never gets to re-decide the loan on its own.
7 min readThe Condo Questionnaire Is Where a Clean File Stalls: Project Warrantability With an AI Agent After the Post-Surfside Rules
A warrantable borrower in an unwarrantable project is a denied loan, and the project review is the slowest, least-staffed part of mortgage underwriting. How an AI agent assembles condo project eligibility against Fannie Mae SEL-2023-06, the critical-repairs and special-assessment rules effective September 2023, and where the agent has to stop and hand the warrantability call to a human.
7 min readRental Income Is Three Different Numbers and Only One of Them Qualifies the Borrower: AI on the Investment-Property Calculation
A lease says one number, the appraiser's Form 1007 says another, and Schedule E says a third, and an underwriter has to pick the right one under rules that change by occupancy and by how long the borrower has owned the property. How an AI agent produces an auditable rental-income figure under Fannie Mae B3-3.1-08, where the 75 percent factor applies, and the reasonableness call the underwriter still owns.
6 min readThe Guide Changed on Tuesday and You Have 4,000 Loans in Flight: Version-Controlling the Rules an AI Mortgage Agent Reasons Against
Fannie and Freddie update their selling guides constantly, often with several effective dates inside a single announcement, and a loan in your pipeline is governed by the rule that was in force when its application was dated, not the rule in force today. Most AI mortgage tools hardcode the rules and silently drift out of date. A technical account of how we version-control the rulebook, apply the right rule by effective date, and re-plan in-flight loans when the guide moves underneath them.
6 min read
You Ain't Seen Nothin' Yet
Book a Demo
Pack up some of your complex historical files — any loan type, any investor. We run them through intake, income and condition clearing, and in 30 minutes you see every condition we created and cleared efficiently for your own team, and why.
- Any loan type, any agency guideline or custom investor overlays.
- Every finding cited to the guideline or document it came from
Case study highlight
Loan review fell from 4 hours 50 minutes to 47 minutes per file, and 78% of items now clear at high confidence — so QC touches only the exceptions.
Pre-Close QC Agent · Better Mortgage— read the case study