How does the client know if ICE is updating Investor guidelines as a result of an investor announcement?

ICE collaborates with clients to manage regulatory changes. Changes can be identified by ICE, the client, the client vendor networks or by the agency/GSE.

When ICE determines an investor announcement requires updates to the Investor guidelines in InvoicingSM, an announcement is published on the InvoicingSM Home page and the Client Support website. This information is also available to servicers in the Investors Published Guideline Report located on the Reports menu.

Which dates are used as comparison dates for guidelines?

The comparison date can be any of the following dates on the invoice:

• Referral Date
• Legal Action Date
  • Complaint Filed
  • Petition Filed
  • NOD Filed
  • 1st Pub Date
• Order Date
• Petition Relief Date
• Date BK Filed
• Deed-in-Lieu Recorded Date
• Invoice Date

Which guideline date is used to determine if a guideline applies?

The system considers several key dates to determine which guideline applies. If a guideline matching the conditions of the invoice or line item does exist, the system checks to see if it has been deactivated.

If a guideline has a deactivated date, it is no longer active and is not used in determining if an invoice and/or line has exceeded an allowable amount.

A guideline that does not have a deactivated date is considered to be an active guideline. It is a candidate for determining if an allowable amount has been exceeded, provided that the comparison date is on or after the guideline effective date and on or before the guideline expiration date.

To see deactivated guidelines, the Show Deactivated checkbox on the Configure Guidelines screen should be checked.

What does the effective date on a guideline mean?

The effective date on a guideline is the date on which the invoice comparison date must be equal to or greater than in order for the guideline to be used in determining if an invoice and/or line item has exceeded an allowable amount. A guideline can have many different effective dates, but the system will always compare the guideline with the most recent effective date first to determine if an allowable has been exceeded.

What does the expiration date on a guideline mean?

The expiration date on a guideline is the last date that a guideline can be used to determine if an invoice and/or line item has exceeded an allowable amount. Although a guideline can have many expiration dates, the most recent expiration date is evaluated first in conjunction with the most recent effective date. If a guideline exists without an expiration date, the guideline is implicitly expired when another active guideline exists with a more recent effective date.

The guidelines are filtered using this hierarchy until one is found where the comparison date is on or after the guideline effective date, and before the guideline expiration date.

To see expired guidelines, select the Show Expired check box on the Configure Guidelines screen.

What is the guideline selection order?

The scenario below demonstrates how the guideline selection process logic applies the following guidelines matching criteria (see image below) of an invoice with a total invoice amount of $625 and an invoice comparison date of 6/1/2013:

• Since the invoice comparison date is greater than or equal to all of the guideline effective dates, the system must first determine if any of the guidelines are deactivated.
• Since the invoice amount is $625 and the active guideline with the most recent effective date has an allowable amount of $600, the system will apply this guideline and indicate that the invoice exceeded the guideline allowable.
• Although the invoice comparison date of 6/1/2013 is still greater than or equal to the other guidelines with higher allowable amounts, the $650 guideline has been deactivated and the $625 guideline is implicitly expired, since the comparison date on the invoice is also equal to or greater than a more recent active guideline effective date, namely the $600 guideline.
• Although the invoice comparison date of 6/1/2013 is still greater than or equal to the 7/1/1998 effective date for the $400 guideline, it is greater than the 9/29/2010 expiration date on the guideline and causes the system to ignore the guideline. Also, the system would not indicate the invoice exceeded the allowable if this was the only guideline in the system.

Why was there no guideline returned when a guideline existed?

A guideline must exist before it can be evaluated against to determine whether an invoice exceeded an allowable.

InvoicingSM provides the flexibility to add guidelines with a retroactive effective date. This can result in the guideline being entered into the system after the guideline effective date. In that circumstance, if the invoice was submitted before the guideline was created, the guideline would not have been available for determining if the invoice and/or line items exceeded an allowable amount.

To determine when a guideline was entered into the system, users need to access the guideline record using the Guideline Maintenance/Configure Guidelines feature and check the date displayed in the Entered date field.

InvoicingSM does not apply guidelines to General Services invoices.

How do I know if the invoice or line item matched an investor or a servicer guideline?

The Origination field on the Invoice Detail Guideline tab will display Investor if the invoice or line item conditions met an investor guideline and Servicer if the invoice or line item was compared to a servicer guideline. It is possible to have an investor and servicer guideline show on the tab. For example, a servicer guideline could apply at the line item level and an investor guideline at the invoice level.

In addition, the Description field on the Guideline tab displays the guideline(s) that met the conditions on the invoice and/or line item.

What guideline amounts display on the Add/Edit Line Item dialog box?

The guideline allowable amount stored for a guideline that meets the conditions of the line item appears on the Add/Edit Line Item dialog box as follows:

• If no guideline exists, N/A appears next to the respective guideline on the Add/Edit Line Item dialog box.
• If the line item has been made available in the guideline engine but no allowable amount entered, the guideline column appears in the guideline engine as a dash "-".
• If a guideline does exist, the allowable dollar amount appears next to the respective guideline on the Add/Edit Line Item dialog box. This could be $0.00 if the guideline allowable amount was entered as zero (0).

Do exceptions apply to $0 guidelines?

The amount entered in the guideline Allowable field is used to determine if an invoice or line item exceeded the maximum amount. So, if a guideline Allowable field contains a zero dollar amount ($0.00), an exception will be returned on the invoice for any requested amounts over $0.00.

What if there is more than one guideline that applies to my invoice or line item?

When more than one guideline applies, the system uses the guideline that has a specific value, such as Florida, before one with a wide-ranging value, such as All.
If two allowable amounts ((Loan) Total Amount and (Inv) Total Amount) are stored within one guideline record, both amounts will apply to the invoice. In addition, the related Exceeds Allowable exception would also be returned to the invoice for each guideline in this scenario. If two guidelines with the exact same conditions exist and all guideline dates being equal except they have different amounts, the guideline applied is the guideline that was entered into InvoicingSM first; the guideline with the earliest Entered date. The Entered date for a guideline can be viewed by accessing the Configure Guideline search results and clicking Manage on the guideline record.

Why are more fields returned when searching the guidelines on specific departments like foreclosure or bankruptcy than when searching on "ALL" departments?

InvoicingSM returns additional fields when searching on a specific value. For example, when searching on the Foreclosure department, the Judicial field will be returned, but would not be returned when searching on All because data stored in the judicial field does not apply to the Bankruptcy department.

Guidelines returned when searching on All may appear to be duplicates because the additional fields that contain the distinguishing data do not display.

The following additional fields might appear in search results based on the loan type, state, or department selected:

• Chapter
• Pre Conf Svc (Pre Confirmation Service)
• Pre FC Sale ( Pre Foreclosure Sale)
• Ln Cur. When Filed (Loan Current When Filed)
• Col. Inv. Prop. (Collateral investment Property)
• Order Type
• Judicial
• Legal State**
• Vendor
• Subcategory
• Category

** This field is only visible in the servicer guidelines.

What is the difference between an Override and a Catch-All guideline configuration?

A servicer guideline can be created using an Override or Catch-All configuration. Override is the default configuration.

Override

This is used when the servicer wants the servicer guideline to take precedence over an existing or future Investor guideline with the same conditions. This guideline is used if no other guideline exists.

Catch-All

This guideline version is used when the servicer wants to specify amounts to fall back on if an investor or servicer guideline is either not found or does not cover the situation completely. Catch-All guidelines appear as highlighted rows in the search results.

Catch-All Guideline Example

An investor guideline is presently set at $60 for XYZ fee for FHA loans in any state. However, no such Investor guideline exists for VA loan types.

Servicers can create a Catch-All guideline for XYZ fee set at $50 and leave the loan type as the default All setting. Any XYZ fee invoice submitted for FHA loans will fall under the $60 Investor guideline. Any XYZ fee invoice submitted for VA loans will fall back on the $50 servicer Catch-All guideline. If no other guideline exists that meets the conditions of the XYZ fee invoice, InvoicingSM will use this Catch-All guideline.