February 2026

The Leading Resource for Mortgage Originators

February 2026

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10 Data Decoded:

Could inheritance trends quietly rewrite the housing market playbook?

13 RESPA Section 8 and the Digital Age: When likes and selfies become compliance red flags 28 A Market on the Rise: Latino LOs are helping shape future of homeownership 37 The Lender’s Secret Weapon: Critical clauses that keep you out of court

Volume 33: Issue 2

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Volume 33: Issue 2 | February 2026

Scotsman Guide magazine is published monthly by Scotsman Guide Inc. P.O. Box 692, Bothell, WA 98041-0692 TEL: (800) 297-6061 scotsmanguide.com President/CEO Kevin Gray Advertising Sales Operations Manager: Bryan Foos bryanf@scotsmanguide.com Senior Account Manager: Gregory Smith gregorys@scotsmanguide.com Senior Account Manager: Tom MacArthur tomm@scotsmanguide.com Account Manager: George Montemor georgem@scotsmanguide.com Marketing marketing@scotsmanguide.com VP Marketing: Todd Belmond toddb@scotsmanguide.com Editorial editorial@scotsmanguide.com Managing Editor: Luke Baynes lukeb@scotsmanguide.com Editor: Eric Souza ericso@scotsmanguide.com Subscriptions subscriptions@scotsmanguide.com Production production@scotsmanguide.com Publication Production Manager: Julie Murphy Senior Designer: Chuck Howard Accounting accounting@scotsmanguide.com Contributing Authors Tom Davis, Matt Delventhal, Anna DeSimone, Mike Eising, T. Robert Finlay, Chris Harrington, Oralia Herrera, Mary Le,

Non-QM 15

ACC Mortgage Inc. ............................................ Cover Acra Lending............................................................... 22 Alliance Portfolio Private Equity Finance........... 24 Carrington Mortgage Services LLC....................... 16 Center Street Lending................................................. 3 Change Wholesale................................. Back Cover Emporium TPO......................... Inside Front Cover First National Bank of America ............................... 11 Greenbox Loans Inc...................................................... 7 Logan Investments................... Inside Back Cover. NFM Lending ................................................................. 9 RCN Capital.................................................................. 33 Taylor Made Lending LLC........................................ 35

Prime Mortgages 19

FHA / VA / USDA 21

Private Money / Hard Money 23

Correspondent 30

Construction 31

Commercial Lenders 39

Lender Directory 43

Scotsman Guide makes every attempt to ensure the accuracy of information, which all listed lenders verify or update monthly. Because of the production cycle and dynamic nature of the industry, loan product terms and availability may not reflect the latest changes. Please contact lenders directly for the most-recent program details. If you believe data is inaccurate or misrepresented, please email customerservice@scotsmanguide.com. Appear in the Lender Listings To see if you qualify to appear in the magazines or online, email any of the advertising contacts to the right or visit scotsmanguide.com/advertise. Policies and Use Scotsman Guide magazine (ISSN 2154-5871) is made available only to licensed mortgage originators and not to the general public. Subscribe to Scotsman Guide online at scotsmanguide.com/subscribe. For additional copies or to manage subscription information, call (800) 297-6061 or email circulation@scotsmanguide.com. Space on Scotsman Guide ’s cover, lender listings and directory, as well as advertisements listed in this issue, are sold as paid advertising. Scotsman Guide Inc. makes decisions regarding editorial placement and content independent of all advertising influence. More about Scotsman Guide Inc.’s editorial policy: scotsmanguide.com/write. The information and opinions expressed in our editorial articles, advertisements and letters from the editor do not necessarily reflect the opinions of Scotsman Guide Inc. Inclusion of an article or advertisement in Scotsman Guide should not be construed as a recommendation or endorsement by Scotsman Guide Inc. or any of our contributors or advertisers. Scotsman Guide Inc. takes pride in precise reporting of the data found herein. The information found in Scotsman Guide is confirmed or updated monthly from independent sources believed to be reliable. Nonetheless, because of the volume of information reported, occasional errors may occur. We assume no obligation or liability for the accuracy, timeliness or completeness of any information. Because of the nature of the mortgage industry, financial terms and availability of funds are always subject to change without notice. This publication is not intended for use by the general public. Scotsman Guide magazine (USPS 025-513) is published monthly, 12 times a year, by Scotsman Guide Inc., 22118 20th Ave. SE, Suite 129, Bothell, WA 98021-4417. Periodicals Postage Paid at Bothell, Wash., and at additional mailing offices. POSTMASTER: Send change-of-address forms to: Scotsman Guide /Circulation Dept., P.O. Box 692, Bothell, WA 98041-0692. ©2026 Scotsman Guide Inc. No part of this publication may be reproduced in any form whatsoever without written authorization of its publisher. Mortgage professionals may print or photocopy Scotsman Guide ’s lender listings and articles for their internal business use only but may not distribute these materials to third parties.

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Scotsman Guide | February 2026

Volume 33: Issue 2 | February 2026 IN THIS ISSUE

DEPARTMENTS

6 From the Editor In a world of echo chambers, we explore why trusted sources — and a pinch of skepticism — are essential for our mortgage coverage 8 Mortgage Data Spotlight: New York Metro home values are rising across every metro region in the Empire State, from Buffalo to the tip of Long Island 10 Data Decoded The YIMBY solution says build more homes. But could inheritance trends quietly rewrite the housing market playbook?

ARTICLES

18 The Three Lines of Defense for Cybersecurity Compliance

12 Lunches, Likes and Liability Happy hours, hashtags and closing

From GLBA to state privacy laws, cybersecurity compliance is critical. Explore the 'three lines of defense framework' and why Fannie and Freddie mandate robust vendor risk management controls Anna DeSimone Housing Research LLC 20 The Digital Revolution Is Underway The mortgage landscape is fragmented and primed for smarter tech to usher in new industry standards Roby Robertson

photos seem innocent — until regulators connect the dots. Understand how patterns, not intentions, define compliance Michael Eising

28 A Market on the Rise

How Latino loan originators are helping shape the future of homeownership Oralia Herrera NAHREP

26 From Buzzword to Business Driver: AI in Mortgage Marketing

From predictive insights to keystroke savings, explore practical ways lenders can integrate AI responsibly without losing the human touch borrowers trust Chris Harrington Usherpa

32 COMMERCIAL SECTION

Scotsman Guide | February 2026

Daily news, insights and data straight to your inbox

Power your day with The Originator, the essential daily newsletter the mortgage industry counts on.

By Eric Souza From the Editor

Like French Chefs, We Rely on Sources (with a Generous Pinch of Salt)

I regularly consult social media to discern what my industry colleagues think of pressing news topics. I read commentary from sources I trust and lean on those perspectives to develop my understanding of nu- anced issues impacting mortgage and real estate markets. I recognize the ways that social media creates echo chambers, so I also intentionally consider the views of colleagues whose words I consume with a generous pinch of salt. In an era of media overload, it’s important to approach new sources with care. My journalism school professor, the late Howard Seemann, drilled this lesson into his students. He would grace the dingy basement newsroom of The Lumberjack (Cal Poly Humboldt’s student newspaper – Go Jacks!) with “Howard’s Homilies,” a two-column breakdown of the good and the bad of each print issue. Howard enjoyed jokes, many of which were, like his issue reviews, generous and brutal. One stuck with me: “What do a French chef and a journalist have in common? You’re only as good as your sauces.” Our SOURCES (phonetic fun aside) and industry relationships are the reason we’ve succeeded, through boom and bust. Sure, we hear plenty of pitches for promotional content, which even occasionally border on mort- gage propaganda, but we have filters in place to maintain the caliber of writers who fill Scotsman Guide’ s pages. Many of our authors are experts in their lending niche who have shared that expertise with our readers for years. We value those connections. Other authors are new to the pages of Scotsman Guide , and represent our publication’s commitment to delivering original insights from front-line sources navigating constantly changing opportunities in the mortgage business. We give space to these new voices and are pleased to share their analysis on topics we may have overlooked in the past. One new writer featured in the February edition is Mike Eising. His openness and biting wit in LinkedIn posts led to us discussing the role of social media in mortgage compliance. His article, found on page 13, is sharp, incisive and required reading for originators and real estate agents overly eager to post their next success story. Compliance professionals (yes, you’re getting two compliance stories this month!) will be pleased to read a piece from Anna DeSimone, starting on page 18, exploring current trends in cybersecurity. Her article examines what she describes as the “three lines of defense risk man- agement model,” while offering suggestions about best practices for risk management and audit assurance.

This month, you might be surprised to learn how interesting a mort- gage deed of trust can be, and the critical role they play in protecting transactions. In our commercial section, two mortgage litigators explain how business-purpose loans are not as standardized as traditional owner-occupied products and can therefore create gaps in lender protection. Find out about the critical provisions they recommend on page 37. As editor of a publication that features industry insights and analysis written by contributing authors, a growing challenge I face is continuing to deliver the quality our readers have come to expect from Scotsman Guide . We are not the landing page for self-serving advertorials or AI-generated slop. We appreciate the authors in this edition, those who have written before, and those to come. We value their expertise. After all, like Howard said all those years ago, we’re only as good as our sauces. ●

Eric Souza Editor of Scotsman Guide magazine. Reach him at (800) 297-6061 or ericso@scotsmanguide.com.

Scotsman Guide | February 2026

Mortgage Data Spotlight New York

In a New York State of Housing, All Metro Values Rise

Albany

Binghamton

Median Home Price: $354,900 ▲ 7.4% Along the banks of the Hudson River, the Empire State's historic "Capital District" has about 899,000 residents. Metro regions throughout the state all saw strong year-over-year value growth, but with its relatively low cost of living, Albany is an attractive option for many homeowners. Zillow shows Albany's home values have risen con- sistently since 2018, with valuations nearly doubling.

Median Home Price: $204,300 ▲ 10.6% Near the Pennsylvania border in central New York, 250,000 residents live in the greater Binghamton region (historically called the "Triple Cities," including Endicott and Johnson City). The birthplace of IBM and home to SUNY Binghamton, the area is rebounding. Its home values are second to last among the state's metro regions but have increased more than anyplace else, with double-digit year-over-year gains.

Glens Falls

Syracuse

Albany

Rochester

Hudson Valley

Buffalo

Binghamton

Kingston

Poughkeepsie

Elmira

Median Home Price: $822,800 ▲ 9.4% Nassau County is immediately east of New York City, and Suffolk County extends the rest of the way to the tip of this densely populated 118-mile-long island. Despite some of the highest average property taxes in the country for single-family homes, demand is far exceeding supply, putting "Strong Island" home values atop the state list. Long Island

Long Island

New York

What the Locals Say

While most of the country seemingly has slowed, if not depreciated, the upstate New York market has been resilient. We've seen a shift to normalization, however. Certain areas like Monroe and Erie counties continue to see buyers competing like never before. With lower rates in 2026, we could see an inventory increase based on sellers feeling more comfortable leaving behind their historically low pandemic rates. I’m cautiously optimistic of a more normalized marketplace, with continued

Metro Areas

Top 5 and Lowest 5 in each category

Source: National Association of Realtors

Home Prices Q4 2025

Price Growth YoY Q4 2025

1. Binghamton 2. Long Island 3. New York

10.6% 9.4% 7.85%

1. Long Island 2. New York 3. Hudson Valley 4. Kingston 5. Albany 7. Glens Falls 8. Rochester 9. Syracuse 10. Binghamton

$822,800 $772,800 $539,900 $476,900 $354,900 $291,800 $287,300 $280,000 $204,300 $182,400

4. Elmira 5. Albany

7.7% 7.4%

7. Syracuse

6.8%

moderate appreciation for 2026. This will allow buyers to obtain and use all mortgage products, while current homeowners are able to see a return on their home investment.

8. Hudson Valley

6.1% 5.7%

9. Buffalo

10. Kingston 11. Glens Falls

4.7% 4.4%

11. Elmira

LenderSearch Data

*Data collected between Dec. 1, 2024, and Nov. 30, 2025

Tom Hart Production Manager

Median FICO

Median Loan Amount

Median LTV

PrimeLending Rochester, N.Y.

720

$580,000

75%

Scotsman Guide | February 2026

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Scotsman Guide | February 2026

Data Decoded Matt Delventhal Principal Economist Cotality

Hand-Me-Down Housing on the Rise Nationwide Property Transfers

Share of Age 65 Homeowners Who Still Own

Source: Cotality 2025

Source: U.S. Census American Community Survey

T he “yes in my backyard” (YIMBY) movement, backed by supply-and-demand dynamics, offers a simple solution to the housing affordability crisis — just build more houses. But some analysts believe that increased supply may arrive through a separate, more inevitable channel. The baby boomer generation is the largest cohort of seniors in United States history. As they age out of homeownership, some have predicted that a “silver tsunami” of housing supply will cascade onto the market. Cotality’s analysis of the latest national deed records gives some support to this narrative. A new indicator of inheritance events shows that a record-breaking 340,000 homes were inherited in the 12 months ending in October 2025. This represents more than 7% of all property transfers, higher than the share for any previous year. All of this can be seen in the left-hand panel of the chart. In California, where state tax laws reward inheritance, nearly 60,000 homes were handed down over that 12-month period. That totals more than 18% of all property transfers in California in 2025 — and, for the first time ever, is more than double the number of newly constructed homes sold over the same period. Matt Delventhal is a principal economist on Cotality's Office of the Chief Economist team. He researches the impact of demographics on the housing market and attempts to unravel the mysteries of raw listings data. His research on the impact of remote work on real estate demand has been published in journals including the Review of Economic Studies and the Journal of Urban Economics. He has held academic positions at Claremont McKenna College and the University of Southern California.

Are we seeing the beginning of a demographically destined tsunami? Maybe. But Cotality’s analysis of the latest U.S. Census data indicates the wave may not be as big, or arrive as soon, as some hope. The current generation of seniors is staying in their homes longer than previous generations. We can see this in the right-hand panel of the chart. We constructed the data for this chart by adding the number of homeowners born in each of the selected birth years, at age 65 and for each age after that. Then we divided the number of homeowners at each age by the number of homeowners at age 65, to get the share of age-65 homeowners who still own. This allows us to show each birth cohort starting out at 100% of their age-65 homeownership level, then declining over time. The results of this calculation are revealing. More than 22% of home- owners born in 1938 left their homes between the ages of 65 and 75. But only 17% of homeowners born in 1946 left their homes during the same decade of life. If seniors opt to age in place rather than downsizing or moving in with children, their homes will arrive on the market later. If heirs choose to keep parents’ homes for their primary residences — which California tax law incentivizes them to do, for example — those properties may skip the open market entirely. Inheritance is likely to play an increasingly important role in the transfer of property in the U.S. going forward. While this will be a boon for beneficiaries, demographics alone are unlikely to significantly improve affordability in the near term. ●

Scotsman Guide | February 2026

RESPA SECTION 8 AND THE DIGITAL AGE M ortgage lending runs on relationships. Lunches with agents, happy hours, closing photos and friendly social media posts between mortgage loan originators (MLOs) and real estate agents all feel normal. They feel harmless. Often, they are.

But regulators see these moments very differently. While the industry sees friendships, regulators see patterns. Where the industry sees networking, regulators see influ- ence. And once money keeps flowing in one direction, their attention follows it. A single like on a social media post feels tiny. One little tap. Harmless. Nobody is getting hauled into a regulatory review over a single emoji. But regulators do not look at one action. They look at the trail it leaves. One like is nothing. Two likes are still nothing. But 50 likes between the same MLO and the same agent on posts about clos- ings, referrals and “best MLO ever” moments stop being innocent. Patterns speak louder than intentions. It is the digital version of a perfume trail on a jacket, a scrunchie left in the passenger seat or lipstick on a collar. One clue means nothing. But a whole set of clues tells a story. In the eyes of examiners, repeated likes become a “thing of value” because they show attention, signal endorse- ment and create influence. A single like is harmless. A trail of likes is evidence. And regulators are very good at following evidence. It follows the same rhythm as Bobby and Susie in high school. Bobby and Susie start getting cozy and smoochy because they think nobody is watching. But that is never how it works. The moment it happens twice, everyone sees it. And by the third time, the entire school has already decided they are a couple.

Regulators read digital behavior the same way. They do not focus on the first interaction. They focus on what it becomes, especially when it happens in the open. The internet puts everything in the open. It shines a bright light on every pattern. Everything is visible, traceable and recordable. This is exactly why an old saying still matters: “While swinging on the garden gate, love may be blind but the neighbors ain’t.” Regulators are the neighbors, and they notice the patterns long before the people creating them do. Happy hour adds another twist. An MLO buys the first round. The agent posts a selfie holding a beer large enough to need its own flotation rating. The caption reads, “Another smooth closing with the best MLO around.” The drink is not the issue. The public praise following the drink is what looks like marketing. And when this happens every Thursday in the same bar, examiners take note. MLOs see friendship. Agents see fun. Regulators see a pattern that refuses to hide. Closing photos create their own headaches. The most overused one is the “family holding oversized key” picture. The key is always so gigantic it looks stolen from the front door of a giant’s castle. The borrowers grin like they just won a reality show, the title agent lurks in the background hoping to be cropped out, and the MLO posts it online as if posing with a novelty prop were somehow meaningful for housing finance. ⊲

By Michael Eising Chief Compliance and Risk Officer

Layout by Chuck Howard

Scotsman Guide | February 2026

“ This is no longer the ‘what happens in Vegas stays in Vegas’ era. Now, what happens online stays online forever. ”

⊳ Lunches continued from Page 13

These photos reveal everything: age, race, household makeup, family structure and all the demographic clues examiners use to build patterns. When the same MLO keeps posting the same type of family holding a key big enough to double as a snow shovel, the pattern stops whispering and starts yelling. Eventually, the oversized key no longer says, “Welcome home.” It says, “Welcome to the unintentional fair lending exhibit.”

HR is called in and nobody remembers what the original plan was. Online posts behave the same way. A cute tag becomes an endorse- ment. A funny caption becomes a referral. A harmless joke becomes a screenshot saved by an examiner. The original intent can be quickly lost. Regulators can also spot connections the way Taylor Swift fans spot Easter eggs. Swifties once decoded an entire album announcement from nothing more than a pair of snake-themed boots in a single photo. Their theory was correct. Examiners have that same energy. One post is harmless. Two posts raise curiosity. Ten posts create a narrative about influence, even if no one meant to write it. This brings the conversation back to the bowling-bumper truth. Mortgage lending has always lived in a gray zone. Compliance is not there to ruin the game. An MLO can still bowl a strike. A perfect game is still possible. But when the ball keeps bouncing off the bumpers repeat- edly, someone eventually walks down to your lane to see why. Patterns of praise, tags, likes, drinks, closing photos and public gratitude all start to resemble influence. And influence is what attracts examiners. ● ● ● This is no longer the “what happens in Vegas” era. This is the screenshot era. Before posting, tagging, or celebrating publicly, it pays to ask a sim- ple question: “How would this look to someone outside the relationship?” If the answer is even a little unclear, that is usually the answer that matters. Doing the right thing always pays off. And as regulators examine online behavior with the same seriousness once applied to perks and gifts, being careful now will prevent far bigger problems later. ●

What is RESPA Section 8? RESPA Section 8(a) prohibits kickbacks for business referrals involving a federally related mortgage loan. In simple terms, it bans giving or receiving money or anything else of value in exchange for referring settlement services connected to those loans.

Anyone wondering why closing packages are the size of a small ency- clopedia only needs to look at history. Laws often exist because someone at some time in history did the thing the law now bans. That is how states ended up with rules about renting bathing suits or keeping horses off hotel second floors. Mortgage rules grew from the same logic. Section 8 of the Real Estate Settlement Procedures Act (RESPA) tightened because the industry took liberties in past decades. Trips, perks, gifts and arrange- ments that lined up a bit too neatly with referrals helped shape today’s regulatory environment. This is why a “thing of value” still has no dollar number attached. No $25 safe zone. No easy chart. Just patterns. And patterns drive interpretation. Regulators learned this long before social media existed. Anyone who remembers the days when title reps would stroll in with two free plane tick- ets to Vegas understands why regulators stepped in with force. That era ended fast, and for good reason. This is no longer the “what happens in Vegas stays in Vegas” era. Now, what happens online stays online forever. Some of the industry’s online habits resemble a Michael Scott team-building event from the TV show “The Office.” Everyone arrives expecting something simple and fun. Twenty minutes later, it is full chaos, Scotsman Guide | February 2026 14

Michael Eising is a chief compliance and risk officer with more than 35 years of experience in mortgage banking, regulatory compliance and risk management. He develops industry education, speaks nationally on compliance trends and helps mortgage professionals

understand how digital behavior, patterns and everyday actions affect regulatory interpretation. He holds the following designations: CMB, CRCM, MBA, MSML, CMCP, RCMS and CRMP.

Non-QM

7. Min # Mos. Since Bankruptcy or Foreclosure

1. Purchase Max LTV% 2. Rate & Term Refi Max LTV% 3. Cash-Out Refi Max LTV% 4. 2nd Mortgage Max CLTV% 5. Min FICO 6. Max Term (Months)

21. VOE Loans 22. Profit & Loss (P&L) 23. Asset Utilization 24. Jumbo Loans 25. Seconds

16. Foreign Nationals/ITIN 17. Bank-Statement Loans

11. Single-Family Residence 12. Condominiums 13. Townhomes 14. Manufactured/Mobile Home 15. Land/Lot

8. Owner-Occupied 9. Non-Owner-Occupied 10. Vacation Homes

18. Self Employed 19. Stated Income 20. DSCR Loans

Lender Name and Contact Info

Min/Max

2 3 4 5 6 7

8 9 10 11

12 13 14 15 16 17 18 19 20 21

22 23 24 25

200K / 4M 90 90 80

66048036 Y Y Y Y Y Y

Y Y Y

Y Y Y Y Y

5th Street Capital, Inc. www.5thstcap.com sales@5thstcap.com

Premier Non-QM Lender, renowned for our unmatched expertise and seamless solutions that empower our partners to thrive in in a dynamic market. Lending Territory: AZ CA CO CT FL GA ID IL IN LA MD MI MN MT NV NJ NM NC OH OR PA SC TN TX UT WA WY

ACC Mortgage Inc. www.accmortgage.com (877) 349-0501 brokersupport@accmortgage.com

150K / 4M 90 90 80

Y Y Y Y Y Y

Y Y

Y Y Y Y Y Y

We are the oldest Non-QM lender since 1999! We know how to close loans that others turn down. We offer solutions, not just loans. Lending Territory: AR AZ CA CO CT DC DE FL GA ID IL IN KS MI MN MS NC NV OR PA SC TN TX UT VA WA

AD Mortgage www.admortgage.com (855) 226-5100 sales@admortgage.com

50K/8M 9090808062048012 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y

Proprietary Non-QM programs for ALL income types: P&L only, 12-month Bank STMTs, DSCR with no income, Foreign Nationals. 2.75 Lender Credit. Lending Territory: Nationwide except AK HI MN ND PR

Angel Oak Mortgage Solutions www.angeloakms.com (855) 680-3675 info@angeloakms.com

75K / 3M 90 90 80

Y Y Y Y Y Y

Y Y

The Leader in Non-QM Volume and Securitizations since 2013. Lending Territory: Nationwide except AK MA NY VT

Arc Home www.archome.com (215) 360-3884 jgibson@archome.com

100K / 3.5M 90 90 85 80 620 360 24 Y Y Y Y Y Y

YYYYYYYYYY

Arc Home features 80% usage of business bank deposits, 60 month AU, 80% on DSCR, and 90% LTV with no MI. $3.5M loan limit. Lending Territory: Nationwide

Axos Bank www.axosbank.com/partners

150K / 30M 70 65 65 75

36 Y Y Y Y Y Y

Y Y Y Y Y Y

National Portfolio, Non-QM and Conventional Lender, Cross Collateralized, Bridge Lending, Loan amounts to $30M, No Cash Out Limitations. Lending Territory: Nationwide

J. Shoop (858) 753-3157 jshoop@axosbank.com

Lender Name and Contact Info

Min/Max

2 3 4 5 6 7

8 9 10 11

12 13 14 15 16 17 18 19 20 21

22 23 24 25

Carrington Mortgage Services, LLC www.carringtonwholesale.com Jeff Massotti (866) 453-2400 wholesalecontact@carringtonms.com

100K / 3.5M 90 90 80 80 550 480

Y Y Y Y Y Y

Y Y Y

Y Y Y Y

Your First Look for Non-QM, Carrington is built for today’s real-world borrowers with a full suite of Non-Stop Non-QM programs. Lending Territory: Nationwide except MA

100K / 3.5M 90 90 80 90 640 360

Y Y Y Y Y Y

Y Y

Y Y Y Y Y Y

Change Wholesale www.changewholesale.com info@changewholesale.com

Less hassle. More closings. That's the Change Wholesale advantage. Lending Territory: Nationwide except NY MA MO

Deephaven Mortgage www.deephavenmortgage.com Broker Info (844) 346-9475 brokerinfo@deephavenmortgage.com

100K / 5M 95 90 85

Y Y Y

Y Y

Deephaven offers 5 programs to meet your needs - from just miss to investor programs - and we u/w to our own guides (not a pass-through). Lending Territory: Nationwide except AK HI MA MO NY WV

First National Bank of America www.fnba.com/wholesale

50K / 3M 85 85 80

1 YYYYYYYYYYY

Y Y Y Y

Non-QM lender offering 12 month income documentation on all loan programs. ITIN loans. Bank statement program for self-employed borrowers. Lending Territory: Nationwide

Keith Hall (517) 324-8417 resbrokers@fnba.com

FundLoans www.fundloans.com David Hidy (760) 388-5888 dhidy@fundloans.com

200K / 6M 90 90 80 90 660 40

Y Y Y Y Y Y

Y Y Y

Y Y Y Y Y Y

FundLoans offers competitive interest rates, Jumbo QM and Non-QM makes-sense program options with broad exception capabilities. Lending Territory: AZ CA CO CT FL GA HI ID IL MD MT NC NJ NM NV OR SC TN TX UT WA WY

GreenBox Loans Inc. www.greenboxloans.com (800) 919-1086 wholesaleinfo@greenboxloans.com

150K / 3M 95 95 85

Y Y

GreenBox thinks outside the box with a common-sense approach in helping qualified borrowers obtain the financing they need. Lending Territory: AZ CA CO CT DE FL GA ID IL LA MA MD NC NJ NV OK OR PA TN TX VA WA

Scotsman Guide | February 2026

Non-QM

7. Min # Mos. Since Bankruptcy or Foreclosure

1. Purchase Max LTV% 2. Rate & Term Refi Max LTV% 3. Cash-Out Refi Max LTV% 4. 2nd Mortgage Max CLTV% 5. Min FICO 6. Max Term (Months)

21. VOE Loans 22. Profit & Loss (P&L) 23. Asset Utilization 24. Jumbo Loans 25. Seconds

16. Foreign Nationals/ITIN 17. Bank-Statement Loans

11. Single-Family Residence 12. Condominiums 13. Townhomes 14. Manufactured/Mobile Home 15. Land/Lot

8. Owner-Occupied 9. Non-Owner-Occupied 10. Vacation Homes

18. Self Employed 19. Stated Income 20. DSCR Loans

Lender Name and Contact Info

Min/Max

2 3 4 5 6 7

8 9 10 11

12 13 14 15 16 17 18 19 20 21

22 23 24 25

LendingOne LLC www.lendingone.com

70K / 3M 92.5 80 75

680 360

Y Y Y

LendingOne’s TPO program empowers mortgage brokers to boost revenue and expand their business with a direct lending solution. Lending Territory: Nationwide except ND SD AK NV

Mark Zummo-Hurley (561) 257-2870 mzummohurley@lendingone.com

LendSure Mortgage Corp. www.lendsure.com (888) 910-0360 sales@lendsure.com LoanStream www.lsmortgage.com (800) 760-1833 ezqual@lsmortgage.com

150K / 3M 90 90 90

620

Y Y Y Y Y Y

Y Y

LendSure offers a range of Non-QM loans for borrowers that don’t fit conforming guidelines, including alternative documentation loans. Lending Territory: Nationwide

150K / 4M 90 80 80

Y Y Y Y Y Y

Y Y

Y Y Y Y Y Y

One Yr. Self-Employment is now available. Previously W2 now go 12 months of Bank Statements to qualify borrower income. Lending Territory: Nationwide except KS MS NE NY VT

PRMG - Paramount Residential Mortgage Group www.prmg.net (866) 776-4937 you@prmg.net

100K / 3M 90 85 80

Y Y Y Y Y Y Y

Y Y

Y Y Y Y Y Y

PRMG is a leading national lender. We deliver jumbo, FHA, VA and conventional products with a high focus on purchase, pricing and service. Lending Territory: Nationwide except NY

RCN Capital www.rcncapital.com Erica LaCentra (860) 432-5858 info@rcncapital.com Velocity Mortgage Capital www.velocitymortgage.com Jason Haye (866) 505-3863 info@velocitymortgage.com Visio Lending www.visiolending.com Sales Manager (888) 521-0353 loans@visiolending.com

55K / 2M 80 80 75

660 360 24

Y Y Y

RCN Capital is a national, direct, private lender. We specialize in Short Term Renovation and Long Term DSCR Rental loans. Lending Territory: Nationwide except AK ND NV SD VT

75K / 5M 75 75 75

Y Y

Y Y Y Y

Alternative mortgage programs for the purchase or refinance of 1-4 investment, multifamily, mixed-use and small commercial properties. Lending Territory: Nationwide except MN ND SD VT

45K / 2M 75 70 70

Y Y Y

Y Y

Fast, simple and dependable rental loans for residential investors. No personal DTI. 30-yr term. Small Balance Commercial now available. Lending Territory: Nationwide except AK DE ID MN ND NE OR RI SD UT VT

Feb. 1-4 MortgageCon 2026: The Magic of Mortgages Universal Orlando Orlando, FL www.mortgagecon2026.com

Mar. 15-17 NPLA Conference March Loews Miami Beach Hotel Miami, FL www.nplaconference.com

Happenings

Feb. 8-11 MBA CREF Manchester Grand Hyatt

Mar. 18-20 CMA 2026 Spring Conference Balboa Bay Resort Newport Beach, CA www.californiamortgageassociation.org

Professional Mortgage Industry Events, Conferences and Trade Shows

San Diego, CA www.mba.org

Mar. 12-13 IMN Bank Special Assets (East) JW Marriott Miami Turnberry

Mar. 22-24 MBA NJ 42nd Annual Regional Conf. of MBAs

Oceans Casino Atlantic City, NJ www.mbanj.com

Adventura, FL www.imn.org

Scotsman Guide | February 2026

The Three Lines of Defense for Cybersecurity Compliance Best practices for risk management and audit assurance By Anna DeSimone

Anna DeSimone is president of Housing Research LLC and provides consulting services and policy devel- opment in the areas of fair lending, loan operations, quality control, servicing and information security. She has written over 40 industry handbooks published by AllRegs, the MBA of America and the Federal Reserve Bank of Boston. www.housingresearchpress.com States with explicit requirements as a condition of licensing or ongoing compliance include California, Connecticut, Illinois, Maryland, Massachusetts, Nevada, New York, Texas and Vermont. States requiring reference to GLBA and the FTC Safeguard Rule in the Nationwide Multistate Licensing System (NMLS) include Florida, Georgia, North Carolina, Ohio and Washington. The era of comprehensive state privacy laws began in 2020 with the California Privacy Rights Act, followed by the rapid spread of state legislation. Every U.S. state now requires mortgage lenders to maintain an information security program. While GLBA applies nationwide, most states have duplicated or expanded upon federal laws for licensees regulated by their Department of Financial Institutions, Department of Banking or similar agency. T he foundation of modern financial privacy in America began in the year 1999 with the enactment of the Gramm-Leach-Bliley Act (GLBA). Over the next 10 years, the financial services industry saw the introduction of more regulations aimed at protecting confidential consumer information. The GLBA Safeguards Rule (16 CFR Part 314), enforced by the Federal Trade Commission (FTC), requires financial institutions to protect the security, confidentiality and integrity of customer information. Companies subject to FTC jurisdiction include mortgage brokers, mortgage lenders, collection agencies, credit counselors, financial advisers, tax prepa- ration firms, payday lenders and other entities engaged in activities that are financial in nature or incidental to financial activities. The FTC updated the Safeguards Rule in 2024, requiring all covered entities to establish a writ- ten information security program and a documented security risk program. The amended rule also requires entities to report certain data breaches and security incidents to the FTC.

The Three Lines of Defense Risk Management Model

Failure to maintain a plan can result in enforcement actions or license suspension. Companies have been fined for lacking written information security plans, encryption policies or incident response procedures. Penalties vary by state but typically include civil fines between $25,000 and $250,000 per violation. Enforcement actions can include cease-and- desist consent orders requiring immediate corrective actions, required adoption and submission of a compliant information security plan or man- dated third-party audits for 12 to 24 months. The Conference of State Bank Supervisors (CSBS) and state regulators work together to create consistent regulatory standards for nonbank firms through the adoption of model laws. CSBS’s model laws provide a clear nationwide framework for state legislatures to enact and state regulatory agencies to implement. The Nonbank Model Data Security Law is largely based on the FTC Safeguards Rule. It requires companies to develop, implement and main- tain a comprehensive, written information security program that contains administrative, technical and physical safeguards that are appropriate to the company’s size and complexity, as well as the nature and scope of its activities. Government-sponsored enterprises Fannie Mae and Freddie Mac announced information security requirements that went into effect in September 2025. Fannie’s requirements are published in its Information Security and Business Resiliency Supplement, requiring lenders, servicers and third-party originators (TPOs) to maintain robust information security and data protection programs. Freddie’s requirements for information security and business continuity planning are published in sections 1301 and 1302 of its seller/servicer guide. ⊲ First Line: Operational teams implement access controls, security settings and protocols for internal and vendor systems ⊲ Second Line: Policy and compliance teams set standards, monitor controls and report cybersecurity risks to leadership ⊲ Third Line: Independent auditors assess overall risk framework effectiveness and certify compliance with industry standards

Scotsman Guide | February 2026

Prime Mortgages

Occupancy: O = Owner-Occupied V = Vacation Home N = Non-Owner-Occupied

Purpose: P = Purchase R = Rate and Term Refi C = Cash-Out Refi

Fixed, ARM, Hybrid: F = Fixed Interest Rate A = Adjustable Rate Mortgage (ARM) H = Hybrid

# Units

Max Loan Amount

Max LTV

Min FICO

DTI Ratio %

Fixed, ARM, Hybrid

ARM Terms

Program Comments

Program Name

Occ

Purp

(855) 226-5100 www.admortgage.com 1234@admortgage.com

AD Mortgage Lending Territory: Nationwide except AK HI MN ND

High Balance Home Ready

OVN

PRC

1-4 1-4 1-2

1.2M

97 97 80

620 620 700

50 50 45

5/6, 7/6, 10/6

FNMA Guidelines - No overlays

802K 2.5M

RefiNow and Refi Possible

Prime Jumbo F Full spectrum of Conventional, Government and Non-QM products. Prime Jumbo — AUS only, DTI up to 55%. 24-Hour Turnaround Time! OV PRC

(617) 899-1428 www.flcbmtg.com alefebvre@flcb.com

FLCBank Florida Capital Bank N.A. Lending Territory: Nationwide except AK HI

Conforming Fixed Rate/ARM

OVN

PRC PRC PRC

1-4

726K

97 80 45

5/6, 7/6, 10/6 5/1, 7/1, 10/1

DTI per AUS

Preferred Jumbo

OV OV

1 1

720 680

A A

65% LTV up to $4MM

HELOC

350K

DTI 45% for CLTV up to 89.99%

Check out our new products and pricing. Now offering a 15-year fixed 2nd mortgage product with a CLTV to 95%.

(800) 760-7833 www.loanstreamwholesale.com wholesalemarketing@lsmortgage.com

LoanStream Lending Territory: Nationwide except KS MS NE NY VT

Agency Conforming

OVN

PRC

765.6K 765.6K 765.6K

97 97 95

620 620 620

50 50 50

FA FA FA

5/1, 7/1, 10/1 5/1, 7/1, 10/1

Quick Turn Times

Home Possible

1-4 1-4

Great Rates

Agency High Balance

OVN

PRC

7/1, 10/1

County Limits Apply

LoanStream is the ONE lender with Conventional, Government and Non-QM Loans that make you the ONE call from your partners and customers.

(951) 278-0000 www.prmg.net brokerservices@prmg.net DU or LPA A/E required DU or LPA A/E required DU A/E or LPA A/E required

PRMG - Paramount Residential Mortgage Group Lending Territory: Nationwide

Home Ready Home Possible FNMA/FHLMC High Balance

1-4

726.2K 726.2K 726.2K

97 95 97

300 300 300

50 50 50

OVN

PRC PRC

1 1

FAH FAH

5/1, 7/1, 10/1 5/1, 7/1, 10/1

FNMA/FHLMC Standard Balance OVN

PRMG is a leading national lender. We deliver jumbo, FHA, VA and conventional products with a high focus on purchase, pricing and service.

Service providers must have substantially similar information security. Mandates published by both Fannie and Freddie include a provision whereby service providers who store, process, access or transmit confidential bor- rower information must comply with similar security and business continuity requirements. Known as “supply chain risk management,” companies are expected to develop, document and implement formal vendor risk manage- ment controls to ensure the controls for new and existing vendors align with — and are as protective as — the company’s information security program. The widely used model for implementing an information security pro- gram is known as the “three lines of defense risk management model.” The first line of defense applies to the people involved in daily operations and those responsible for making sure the information security program is running smoothly. First-line teams implement access controls, security settings and protocols for internal operations, as well as third-party and fourth-party service providers. Second line of defense teams are tasked with establishing policy, standards and procedures. They provide expertise and guidance and monitor how well the first-line controls work. Second-line teams track compli- ance, perform risk assessment and report cybersecurity risks to leadership.

“ Mandates published by both Fannie and Freddie include a provision whereby service providers who store, process, access or transmit confidential borrower information must comply with similar security and business continuity requirements. ”

The third line of defense provides objective and independent assurance. Internal or external auditors evaluate the effectiveness of the entire risk management framework, including controls managed by the first two lines. Auditor reports generally include attestations certifying compliance to indus- try standards such as the National Institute of Standards in Technology (NIST) framework, the International Organization for Standardization (ISO 27001) or Service Organization Controls 2 (SOC 2). ●

Scotsman Guide | February 2026

The Digital Revolution Is Underway The mortgage landscape is fragmented and primed for smarter tech to usher in new industry standards By Roby Robertson

D espite the U.S. mortgage industry’s prominence — it serves more than $13 trillion in debt across about 86 million mortgages — it remains one of the most complex and inefficient financial sectors in the nation’s economy. This is largely because it hasn’t fully embraced the digital transformation that has made other sectors like banking, payments and insurance more structured and consumer-friendly. As a result, the entire home lending process, from origination and servicing to closing, continues to rely on disconnected systems, manual data entry and outdated workflows. This results in higher costs and greater frustration for customers. According to the Mortgage Bankers Association (MBA), lenders spend approximately $12,500 to originate a mortgage. These costs are often passed on to customers, making mortgages more expensive and putting homeownership out of reach for many Americans. The current lending dynamic is also negative for mortgage companies. Even though new originations are estimated to be worth roughly $2 trillion per year, according to LoanLogics calculations on MBA data, lenders are only earning about $2.7 billion in net revenue on that amount — a roughly 4% profit margin. A mortgage revolution is long overdue. Fortunately, the technology needed to make the industry more efficient and profitable already exists. Disconnected and risky systems The mortgage industry today is a complex web of participants across different systems, data standards and workflows. While much of the industry has already invested in sleek borrower-facing websites and apps, little movement has been made to improve the infrastructure underneath these platforms. There’s lots of style, but little substance. In fact, mortgages mostly still rely on loan origination platforms that were built decades ago with limited application programming interface (API) capabilities, and integrations that are bolted on, not natively designed. It’s like buying a $250,000 sports car and driving it on a 30-year-old road

Roby Robertson was formerly executive vice president of origination technology strategy at LoanLogics, a leader in loan technology for the mortgage industry. Robertson has more than 15 years of experience driving innovation in fintech and mortgage technology. He was previously senior vice president of product development at LoanBeam, a provider of income calculation and verification technology. Cloud-based future The most important change that needs to happen for the industry is a full migration to cloud-based infrastructure, replacing siloed and gated systems with interoperable platforms that promise secure data, portable files, easy collaboration and simple updating. On this new foundation, AI-powered automation can handle repetitive, error-prone tasks that take significant time and resources. These include document recognition, income verification, fraud detection and compliance checks, all of which can be automated with higher accuracy and lower cost. riddled with potholes. It’s difficult to accelerate with bad infrastructure underneath, no matter how much horsepower you have. Worse than the slowdown is the redundancy. These different systems are often incompatible with one another, meaning that information gets entered multiple times, converted into multiple formats and passed along from com- pany to company. As a result, much of the mortgage process still revolves around document management rather than structured data exchange. The important data in a loan file is held captive in static formats: PDFs, emails, Word documents and even faxed forms. Every time the data changes hands or formats, it must be manually replicated across multiple systems. This redundancy adds cost and complexity and increases the likelihood that mistakes will arise as data is ported from system to system in a long game of “mortgage telephone.” A single loan file is typically touched by dozens of hands, each of them rechecking or reentering the same infor- mation, which results in delays and opportunities for error. This ultimately reduces per-loan profitability.

Scotsman Guide | February 2026

FHA/VA/USDA

Purpose: P = Purchase R = Rate and Term Refi C = Cash-Out Refi

Fixed, ARM, Hybrid: F = Fixed Interest Rate A = Adjustable Rate Mortage (ARM) H = Hybrid

Credit Events: BK 7 = Chapter 7 Bankruptcy BK 11 = Chapter 11 Bankruptcy FC = Foreclosure

Occupancy: O = Owner-Occupied V = Vacation Home N = Non-Owner-Occupied

Seasoning

Fixed, ARM, Hybrid

# Units

Max Loan Amount

Max LTV

Min FICO

DTI Ratio %

ARM Terms

Program Comments

BK 7 BK 11

Program Name

Occ

Purp

(617) 899-1428 www.flcbmtg.com alefebvre@flcb.com

FLCBank Florida Capital Bank N.A. Lending Territory: Nationwide except AK HI

HomeReady/Home Possible

726.2K 97

640

LPMI Available

FHA Purchase

1-4

970.8K 96.5 620

5/1

$ by county, DTI per AUS

1-4

726.2K 90 620

5/1

DTI per AUS

Rural Housing

100

No specific loan limit

AUS Approved Eligible.

(800) 760-1833 www.loanstreamwholesale.com wholesalemarketing@lsmortgage.com

LoanStream Lending Territory: Nationwide except KS MS NE NY VT

FHA Rate/Term Refinance

1-4

331.8K 97.5 600 55 24

County loan limits apply

FHA Cash-Out Refinance

1-4

331.8K 80 640 55 24

County loan limits apply

FHA Purchase

1-4

331.8K 96.5 600 55 24

County loan limits apply

VA Purchase

1-4

1M 100 620 60 24

County loan limits apply

600 Min FICO and great rates. Knowledgeable Account Executives and fast ops are ready to serve you.

(951) 278-0000 www.prmg.net brokerservices@prmg.net

PRMG - Paramount Residential Mortgage Group Lending Territory: Nationwide

FHA

1-4

1.3M 98 580

5/1

620 3-4 Unit

1-4

1M 100 580

3/1, 5/1

620 3-4 Unit

USDA

1M 100 620

FHA Streamline

1-4

580

5/1

620 High Balance; 620 2-4 Unit

PRMG is a leading national lender. We deliver jumbo, FHA, VA and conventional products with a high focus on purchase, pricing and service.

Machine learning models training on millions of data points, sample documents and workflows can flag anomalies, assess borrower risk and even predict which loans are more likely to close. This helps lenders and brokers work more efficiently and close loans faster. Given the scale of the mortgage market, there is significant data to be gathered in all parts of the process. Analyzing this data can better train models and generate insights to further improve efficiency. With a stronger foundation optimized by smart workflows, collabora- tion and transparency will become the industry’s new currency. Instead of exchanging static files and emails with partial or incorrect information, brokers, platforms and stakeholders will be able to share data in real time through secure APIs. File audits will be completed once and appended with a digital certificate that can follow the loan throughout its lifetime, eliminating the need for redundant checking activities. Individual loan aggregators, investors and servicers will be able to save countless hours of worktime, allowing individuals and teams to spend more time on higher-value activities or better customer service. By investing in smart platforms, mortgage originators can save thousands of dollars in origination costs per loan. Across the entire U.S. mortgage market, this translates to billions in potential savings.

These cost savings will in turn enable originators to scale up their lend- ing efforts and pass along savings to consumers. Mortgage wholesalers, aggregators, diligence firms and investors can also save thousands of dollars per loan by avoiding the time and resources spent on duplicate audit review, and loan servicers can in turn save hundreds of dollars per loan by automating their workflows. ● ● ● The mortgage industry is overdue for a foundational reinvention, but the good news is that the technology to make that possible is available right now. The convergence of cloud-based, AI-driven and collaborative platforms offers a path forward that is faster, more secure and more cost-effective. This will ultimately expand U.S. homeownership by making mortgages more accessible and affordable. Some of the biggest mortgage players are already making moves, and those who embrace technology today will define the standards of efficiency, accuracy and trust that others must follow tomorrow. The mortgage process of the future won’t be measured by paperwork or processing days. It will be defined by data, intelligence and collaboration. The revolution is already underway. ●

Scotsman Guide | February 2026

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