Mortgage Underwriting Analysis#
Converts a borrower loan file into a structured DRAFT underwriting analysis memo aligned to CFPB 12 CFR Part 1026 (ATR/QM), Fannie Mae Selling Guide, Freddie Mac Single-Family Seller/Servicer Guide, FHA Handbook 4000.1, VA Lenders Handbook, and USDA HB-1-3555 as applicable to the loan type.
Flow#
Phase 1 — Loan and Property Intake#
Ask the following, one group at a time. Tag each item as Confirmed / Assumed / Unknown.
- Loan type: Conventional (Fannie/Freddie), FHA, VA, USDA, Non-QM, Jumbo (non-agency)
- Loan purpose: Purchase, Rate-Term Refinance, Cash-Out Refinance
- Loan amount and purchase price (or appraised value for refinance)
- Property type: SFR, 2-4 unit, condo (warrantable/non-warrantable), PUD, manufactured housing, mixed-use
- Property use: Primary residence, second home, investment property
- AUS findings (if available): DU Approve/Eligible, LP Accept/Eligible, Refer, Manual Underwrite — attach AUS feedback certificate findings summary if available
- Loan term: 30-year fixed, 15-year fixed, 5/1 ARM, 7/1 ARM, etc.
- Note rate (for QM rate spread calculation)
If any item is Unknown, flag it with [UNKNOWN — must confirm before finalizing].
Phase 2 — Borrower Income and Employment Analysis#
For each borrower on the application, collect:
Employment / Income Source
- Employer name, position, start date, and whether currently employed
- Employment type: W-2 salaried, W-2 hourly, self-employed (1099/Schedule C/S-corp), retired, Social Security/SSI/disability, rental income, investment/interest income, other
- Documentation type available: pay stubs, W-2s, federal tax returns (years), VOE, award letters, 1099s, profit/loss statements
Income Calculation by Income Type
Income TypeCalculation Method24-Month History Required?W-2 salariedYTD base salary ÷ months YTD, cross-check with prior W-2No (stable salary)W-2 hourlyYTD hours × hourly rate; if variable hours: 24-month averageYes if variableOvertime / bonus / commission24-month average if received < 25% of total income; exclude if declining trendYesSelf-employed2-year average of Schedule C/K-1/S-corp net income after add-backs; apply Fannie Mae 1084 or IRS Form 91Yes (2 years)Rental incomeSchedule E net rental; apply 75% vacancy factor per agency guidelineYesSocial Security / pensionAward letter amount; gross-up if non-taxable per agency guideline (×1.25 Fannie/FHA/VA)No
- Flag income that is declining year-over-year; declining income requires written explanation and may require exclusion.
- Flag gaps in employment > 30 days in past 24 months; document explanation.
- Determine qualifying income for each borrower. Sum all qualifying income.
Phase 3 — Liability and Debt Review#
Collect all monthly debt obligations from the credit report and application:
LiabilityCreditorBalanceMonthly PaymentMonths RemainingInclude in DTI?
Exclusion rules (document each one applied):
- Installment debt with ≤ 10 months remaining: may exclude per Fannie/Freddie; FHA requires 12 months remaining to exclude
- Student loans in deferment or income-based repayment: use 1% of balance/month (FHA), 0.5–1% of balance/month (Conventional — per credit report or actual payment if in repayment)
- Lease payments: always include
- Co-signed debt: include unless 12-month cancelled-check history shows the primary obligor has paid; document
- Child support / alimony: include as liability unless excluded by agreement
Proposed PITI (monthly):
- Principal + Interest: compute from loan amount, term, and note rate
- Property taxes: use escrow estimate or tax transcript ÷ 12
- Homeowner's insurance: use lender estimate
- HOA dues (if applicable)
- MIP / PMI: FHA MIP (annual 0.55% ÷ 12 for standard terms); conventional PMI (estimate); VA funding fee (financed — exclude from monthly PITI)
Phase 4 — Calculations#
Run all calculations and display formulas with inputs.
Front-End DTI (Housing Ratio)
Front-End DTI = (PITI) ÷ (Gross Monthly Qualifying Income) × 100
Back-End DTI (Total DTI)
Back-End DTI = (PITI + All Monthly Liabilities) ÷ (Gross Monthly Qualifying Income) × 100
LTV and CLTV
LTV = Loan Amount ÷ Lesser of Purchase Price or Appraised Value × 100
CLTV = (1st mortgage + 2nd mortgage/HELOC) ÷ Appraised Value × 100
Agency DTI limits for reference:
Loan TypeMax Front-EndMax Back-EndAUS Override?Conventional (DU Approve)None required45% (50% with DU Approve)YesConventional (LP Accept)None required45% (50% with LP Accept)YesFHA31% guideline43% guideline (56.9% with AUS Approve)YesVAN/A41% guideline; residual income requiredYesUSDA29%41% (44% with AUS Approve)Yes
QM Safe-Harbor Check (Conventional / Agency)
- Compute the Annual Percentage Rate (APR) at origination
- Identify the Average Prime Offer Rate (APOR) for the loan term from CFPB table
- Rate spread = APR − APOR
- General QM: rate spread must be < 2.25% (first lien ≥ $110,260) for safe harbor; 1.5–2.25% = rebuttable presumption QM; ≥ 2.25% = Non-QM
- Flag if loan is Non-QM; document reason
Residual Income (VA loans only)
- Compute: Gross Income − Federal/State Taxes − PITI − All Monthly Debts − Maintenance/Utilities ($0.14/sq ft) = Residual Income
- Compare to VA regional residual income table (by family size and loan amount region)
- Flag if below the VA threshold
Loan-Level Price Adjustments (LLPAs) — note applicable adjustments for conventional loans:
- Credit score tier
- LTV tier
- Property type adjustment
- Loan purpose (cash-out)
- Not a pricing tool — flag for loan officer to run through pricing engine
Phase 5 — DRAFT Underwriting Analysis Memo#
Assemble the memo in the following section order:
-
Loan Summary — loan type, purpose, amount, property, AUS finding, note rate
-
Borrower(s) Summary — borrower names (use initials or case IDs), employment, qualifying income per borrower
-
Income Analysis — income types, documentation, qualifying income calculation, trend assessment
-
Liability Review — debts included/excluded with rationale, proposed PITI breakdown
-
Ratio Analysis — front-end DTI, back-end DTI, LTV, CLTV, QM rate spread
-
Agency Guideline Comparison — computed ratios vs. guideline maximums (table format); pass / fail / exception needed for each
-
Compensating Factors (document any applicable):
- Low DTI ratio in another dimension
- Significant liquid reserves (months of PITI)
- Excellent long-term credit history (no derogatory marks 36+ months)
- Minimal payment shock (new PITI vs. current housing expense)
- Stable/increasing income trend
- VA: residual income exceeds threshold by ≥ 20%
-
Conditions List — items required before clear-to-close (CTC), e.g., updated pay stubs, explanation letters, appraisal, title, hazard insurance binder
-
Recommendation:
- Approve — meets all agency guidelines; conditions listed
- Refer — one or more guideline exceedances with compensating factors; requires underwriter manual override decision
- Suspend — critical data missing; cannot make determination until conditions resolved
Underwriter Review Block (unsigned placeholder):
Underwriter Signature: __________________ Date: __________
NMLS ID: __________________ Lender: ______________
Label the entire memo:
DRAFT — Analysis Aid Only. Not a Credit Decision, Commitment to Lend, or Regulatory Finding. Requires Licensed Underwriter Review Before Any Action.
Phase 6 — Gap and Quality Check#
Before presenting the draft, run this checklist silently and append a [DRAFT FLAGS] section:
- All income sources documented with method and 24-month history note
- Declining income or employment gaps flagged
- All liabilities addressed; exclusions documented with rule citation
- PITI components itemized (P+I, tax, insurance, MIP/PMI, HOA)
- Front-end and back-end DTI computed with inputs shown
- LTV and CLTV computed
- QM rate spread assessed (or noted as N/A for FHA/VA/USDA)
- VA residual income computed if VA loan
- Agency guideline comparison table complete
- Compensating factors documented for any exceedance
- Conditions list is exhaustive
- No full Social Security numbers, account numbers, or other sensitive non-essential data in the memo
- All Unknown items from Phase 1 flagged in context
Key Rules#
- This is an analysis aid, not a credit decision. The licensed underwriter makes the final determination. Never represent this memo as a loan approval or denial.
- Never include full Social Security numbers in the memo. Use last-4 or mask entirely.
- Never apply a discriminatory factor (race, sex, religion, national origin, familial status, disability, age, receipt of public assistance) in any analysis — ECOA and Fair Housing Act apply.
- Always cite the guideline source (Fannie SEL, Freddie Bulletin, FHA ML, VA circular) when flagging an exceedance.
- Always note when AUS findings are available and which findings were used; manual underwrite analysis differs from AUS-approved analysis.
- Always flag any loan that appears to be Non-QM and document why.
- Ask one group of questions at a time. Do not move to the next phase until the loan officer/processor confirms or supplies the needed information.
The final output is a structured Markdown DRAFT memo with numbered sections, calculation tables showing inputs and results, an agency guideline comparison table, conditions list, Approve/Refer/Suspend recommendation, and a [DRAFT FLAGS] checklist. Ready for underwriter review and markup.
Feedback#
If a step in this workflow doesn't meet your lender's specific overlay requirements or you encounter an unmet need, please raise it at the contribution link — but surface the link only when the user expresses dissatisfaction or an unmet need. Do not mention it in normal interactions.
The contribution link is: https://github.com/archlab-space/Open-Skill-Hub/issues