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Non-QM Mortgage Underwriter

Position Summary

The Non-QM Mortgage Underwriter is responsible for the comprehensive credit, income, asset, collateral, and compliance review of residential mortgage loans that fall outside traditional Agency and Qualified Mortgage (QM) guidelines.

The Underwriter evaluates each loan based on applicable investor guidelines, Bank credit policy, regulatory requirements, and sound underwriting principles to determine the borrower’s ability to repay and the overall acceptability of the credit risk.

This position requires significant experience with Non-QM products, including bank statement, asset utilization/depletion, debt service coverage ratio (DSCR), investor cash-flow, alternative documentation, jumbo, and other non-Agency residential mortgage programs.

Essential Duties and Responsibilities

Credit Underwriting

• Perform complete underwriting analysis of Non-QM residential mortgage loan applications.
• Evaluate borrower credit history, liabilities, liquidity, reserves, assets, income, employment, occupancy, and overall credit profile.
• Determine whether loans meet applicable Bank and investor credit and eligibility requirements.
• Analyze compensating factors and layered risk when evaluating loans with multiple risk characteristics.
• Review credit reports, fraud reports, verification documentation, title information, and other supporting documentation.
• Identify inconsistencies, red flags, potential fraud, and documentation deficiencies.
• Apply prudent underwriting judgment when guidelines require interpretation or escalation.

Non-QM Income Analysis

Perform detailed analysis of traditional and alternative income documentation, including:

• Personal and business tax returns.
• W-2 and salaried income.
• Self-employed borrower income.
• Bank statement programs, including personal and business bank statements.
• Profit-and-loss statement programs.
• 1099 income programs.
• Asset utilization and asset depletion programs.
• Rental and investment-property income.
• DSCR and property cash-flow programs.
• Other alternative documentation programs permitted by approved investor guidelines.

The Underwriter must understand the differences among investor methodologies and correctly apply the applicable calculation methodology to each loan.

DSCR and Investor Property Underwriting

• Calculate and validate DSCR in accordance with applicable program and investor requirements.
• Review lease agreements, market rents, appraisal rental schedules, taxes, insurance, HOA expenses, and other required property information.
• Determine property and borrower eligibility for business-purpose and investor-property loan programs.
• Identify circumstances requiring additional documentation or escalation.

Collateral Review

• Review residential appraisals for completeness, consistency, marketability, and compliance with applicable program requirements.
• Evaluate comparable sales, adjustments, property condition, market trends, and unusual property characteristics.
• Review automated valuation models, appraisal review products, desk reviews, field reviews, and other collateral documentation when required.
• Identify appraisal or property issues requiring escalation to management, appraisal review, or the investor.

Investor and Secondary Market Eligibility

• Underwrite loans to approved Non-QM investor guidelines and Bank credit policy.
• Maintain working knowledge of multiple investor matrices, overlays, exceptions, and documentation requirements.
• Ensure loans are structured to meet the requirements of the anticipated secondary-market execution.
• Identify potential investor eligibility or salability issues before final loan approval.
• Work with Secondary Marketing and Capital Markets personnel to resolve investor eligibility questions and determine appropriate loan execution.
• Assist in addressing investor suspense conditions, post-purchase inquiries, and underwriting-related conditions when necessary.

Compliance and Ability-to-Repay

• Evaluate loans for compliance with applicable federal and state mortgage lending requirements.
• Apply applicable Ability-to-Repay requirements to consumer-purpose Non-QM transactions.
• Understand the distinction between consumer-purpose Non-QM lending and applicable business-purpose/investor-property transactions.
• Review documentation for consistency with loan purpose, occupancy, product eligibility, and applicable regulatory requirements.
• Escalate potential compliance concerns before final approval.

Loan Decisions and Conditions

• Issue clear underwriting decisions, including approval, conditional approval, suspension, counteroffer/restructure recommendation, or denial within delegated authority.
• Establish appropriate underwriting conditions necessary to support the credit decision.
• Review submitted conditions and determine whether underwriting requirements have been satisfactorily addressed.
• Document underwriting rationale clearly enough to support internal review, quality control, investor review, regulatory examination, and audit.
• Escalate policy exceptions and loans outside delegated authority to the appropriate credit authority.

Exceptions and Risk Management

• Identify loans requiring policy, guideline, or investor exceptions.
• Prepare clear written explanations of the risk presented and applicable compensating factors.
• Do not approve exceptions outside established underwriting authority.
• Escalate material credit, compliance, fraud, collateral, or investor eligibility concerns to management.
• Maintain independence of underwriting judgment and avoid inappropriate influence from production personnel.

Quality Control and Post-Closing Support

• Assist with responses to pre-funding and post-closing quality-control findings.
• Respond to investor purchase conditions and underwriting questions.
• Assist with remediation of documentation deficiencies.
• Participate in analysis of underwriting defects, repurchase requests, early payment defaults, and investor trends when applicable.
• Provide feedback regarding recurring underwriting, processing, documentation, or origination issues.

Performance Expectations

The Non-QM Mortgage Underwriter is expected to maintain:

• High-quality and consistent credit decisions.
• Compliance with Bank and investor guidelines.
• Appropriate underwriting turn times.
• Low material defect rates.
• Low investor suspense and purchase-condition rates.
• Complete and defensible underwriting documentation.
• Appropriate identification and escalation of exceptions and risk.
• Professional communication with production, operations, compliance, secondary marketing, and management.

Production volume or turn-time expectations shall not override the Underwriter’s responsibility to make independent and prudent credit decisions.

Required Qualifications

• Minimum 5 years of residential mortgage underwriting experience preferred.
• Minimum 2–3 years of direct Non-QM or non-Agency underwriting experience strongly preferred.
• Demonstrated experience underwriting bank statement, DSCR, jumbo, self-employed, asset utilization/depletion, and alternative-documentation loans.
• Strong knowledge of residential mortgage credit analysis.
• Strong understanding of self-employed borrower and business cash-flow analysis.
• Experience working with multiple Non-QM investors and investor-specific guidelines.
• Knowledge of Ability-to-Repay requirements and applicable residential mortgage regulations.
• Strong understanding of appraisal and collateral analysis.
• Experience with loan origination systems, automated underwriting tools, fraud-detection systems, and investor portals.
• Strong analytical, organizational, written communication, and decision-making skills.

Preferred Qualifications

• Experience underwriting loans for secondary-market sale.
• Experience with delegated underwriting authority.
• Experience underwriting both consumer-purpose Non-QM and business-purpose DSCR/investor loans.
• Experience with jumbo and complex high-net-worth borrowers.
• Experience working within a bank or regulated financial institution.
• Familiarity with quality control, investor due diligence, loan purchase reviews, and repurchase-risk management.

Authority and Accountability

The Non-QM Mortgage Underwriter operates within delegated underwriting authority established by the Bank and/or applicable investor.

The Underwriter is accountable for ensuring that each approved loan is supported by appropriate documentation, meets applicable credit and investor requirements, and presents an acceptable level of risk.

Loans outside established authority, policy, or investor guidelines must be escalated to the appropriate approval authority. The Underwriter may not approve his or her own exception beyond delegated authority.

Independence

The underwriting function shall maintain appropriate independence from mortgage production. Compensation and performance management for the Underwriter shall not be structured in a manner that encourages approval of loans that do not meet applicable credit, regulatory, or investor requirements.

The Underwriter is expected to exercise independent professional judgment and has the authority and responsibility to suspend, decline, condition, or escalate a loan when the credit risk, documentation, compliance, collateral, or investor eligibility does not support approval.