United Wholesale Mortgage

VA Refinancing

Product Owner, Regulatory Compliance & Fees•2016 – 2020

In September 2017, Senator Elizabeth Warren called for an overhaul in how VA loans—particularly refinances (VA IRRRLs)—were originated. She pushed for stricter restrictions on what fees could be charged, what interest rates could be offered, and what recoupment time period was acceptable to close these loans. This became my key focus in the compliance department following her announcement. I was put in charge of rebuilding underwriting, compliance, and closing controls around VA loans, and ensuring newly created/updated documents were added to our origination packages.

The task:

Rebuild compliance controls across the loan origination system to ensure no VA loan exceeded permissible fees, and implement a strict recoupment calculator in the closing portal to validate compliance
Put a stopgap in place immediately so no loans slipped through while system controls were being updated
Coordinate with Underwriting, Sales, and Closing to ensure consistent communication to brokers, and correct system changes to support the new guidelines

The challenge:

The change was effective immediately—there was no stated enforcement date—so the controls had to be overhauled fast, and a Day 0 stopgap had to be in place
The guidance was vague on what fees were permissible, and in mortgages fees can vary widely by state and municipality (and even have different names for the same thing)
The loan needed to be compliant at closing, but controls had to be installed throughout the origination process to avoid major restructuring at the closing stage
The entire company needed to be trained on the updated guidelines

The approach:

Built an internal calculator (using tools like Excel) and distributed it across the company so team members could consistently and accurately validate compliance at each stage of the loan
Created training documentation for Sales, Underwriting, and Closing to align internal teams and set clear expectations with customers/brokers
Partnered closely with the compliance development team to implement each new system control step-by-step and validate behavior through the workflow
Served as the reference point across teams to ensure a single, consistent compliance flow was followed end-to-end
Worked with the document generation vendor to update impacted origination documents and create new ones where needed

Learnings:

In a highly regulated space like mortgages, the government can change the rules quickly—being flexible and having an immediate stopgap mindset is critical
When rules are vague, pick a defensible interpretation and stick to it. If you change direction every time someone has a new take, the project never finishes
Distribute knowledge widely and clearly. Being the SME for the whole company can turn you into a bottleneck fast, so sharing the context is important for both execution and customer experience