Lenders Compliance Group®
Creating a Culture of Compliance®
MEMBER OF NATIONAL ORGANIZATIONS
ABA | MBA | NAMB | AARMR | MISMO | ARMCP | ALTA | IIA | ACAMS | IAPP | MERSCORP
BCG Solutions
Continuous Compliance
Ongoing regulatory compliance guidance:
- Cost effective monthly or hourly compliance.
- A dedicated Compliance Manager to provide regulatory compliance guidance.
- Applicable federal, state and local legal and regulatory requirements (i.e., including statutes, rules, regulations and ordinances).
- Applicable requirements and guidelines of each governmental and quasi-governmental agency, board, commission, instrumentality and other governmental body or office having jurisdiction.
- Reasonable and customary mortgage practices of prudent mortgage broker and mini-correspondent compliance administration in mortgage banking, involving the origination of mortgage loans.
- The standards that mortgage brokers and mini-correspondents should employ and exercise in originating and administering mortgage loans (if applicable).
- Cost-effective policies and procedures that meet regulatory scrutiny, including requirements and Best Practices relating to mortgage broker and mini-correspondent loan originations and applicable mortgage acts and practices.
Quality Control
Auditors evaluate each sampled loan file to determine whether the file meets applicable agency and program guidelines including, but not limited to: Fannie Mae, Freddie Mac, FHA, VA, USDA/RHS, FHLB, HECM, HELOCs, Portfolio. Request Information
Hands-On Compliance
State of the Art Technology
Core Audits Processes
Documentation Review
Federal Compliance
State Compliance
Underwriting Review
Desk Appraisal Review
Reverifications and Revalidations
Data Integrity Review
Field Appraisal Review
Credit Risk Analysis
Unique Summary Report
Trend and Defect Analyses
Other QC Services Available
Pre-Funding
Post-Closing
Delinquent Loans & EPDs
Fraud Detection
Sampling Methodology
Random
Statistical Sampling
AML Testing
Testing annually is recommended, but not later than every eighteen months. An audit of the procedures detailed in an RMLO’s policy and procedures must be conducted either internally, in accordance with FinCEN guidelines, or, in accordance with FinCEN guidelines, by an independent, external auditor entirely independent of the company’s BSA Officer. Request Information
- Audit responses to Prior Year Consulting and Regulatory Examination Reports, if applicable.
- Entrance Interview.
- Issue and Review Document Request.
- Conduct Anti-Money Laundering (AML) Risk Assessment.
- Review:
- AML Compliance Program Oversight.
- Customer Identification Program Oversight.
- Suspicious Activity Reporting (SAR) Policies and Procedures.
- Suspicious Activity Monitoring Systems.
- Transaction Testing, consisting of a sample of filed Suspicious Activity Reports (SARs) in order to determine completeness.
- Information Sharing Practices under Section 314(a) and 314(b) of the USA PATRIOT Act.
- Reporting of Cash Payments Over $10,000 (FinCEN Form 8300), if applicable.
- Report of Foreign Bank and Financial Accounts (IRS Form TD F 90-22.1), if applicable.
- Report of International Transportation of Currency or Monetary Instruments (FinCEN Form 105), if applicable.
- Issue an Audit Report containing Findings and Recommendations.
- Exit Interview.
Policies and Procedures
We offer our clients real world, practical solutions to mortgage compliance issues, emphasizing operational assessment and improvement, benchmarking methodologies, Best Practices, regulatory compliance, and mortgage risk management. Request Information
Our policies and procedures support the applicable regulatory requirements as well as meet the needs of the loan originator’s business model, including:
Advertising Manual
Anti-Money Laundering (AML) Program
Appraiser Policy Statement
Consumer Complaints
Customer Identification Program (CIP)
E-Sign Procedures
Fair Credit Reporting Act (FCRA)
Fair Lending
Identity Theft Prevention – Red Flags Rule
Information Security Plan
Loan Originator Compensation
Mortgage Acts and Practices: Policies and Procedures
Privacy
Quality Control Plan
Real Estate Settlement Procedures Act (RESPA)
Regulation B (ECOA)
SAFE Act
Social Media
TILA/RESPA Integration Disclosure (TRID)
Truth-in-Lending (TILA)
Unfair, Deceptive, or Abusive Acts or Practices (UDAAP)
Vendor Management
Quality Control
Auditors evaluate each sampled loan file to determine whether the file meets applicable agency and program guidelines including, but not limited to: FANNIE MAE, FREDDIE MAC, FHA, VA, USDA/RHS, FHLB, HECM, HELOCS, PORTFOLIO.
Policies and Procedures
Real world, practical solutions to mortgage compliance issues, emphasizing operational assessment and improvement, benchmarking methodologies, Best Practices, regulatory compliance, and mortgage risk management. Our policies and procedures support the applicable regulatory requirements as well as meet the needs of the loan originator’s business model.
Mini-Correspondent
Policies, procedures, and requirements relating to mini-correspondent loan originations and applicable mortgage acts and practices
AML Testing
Test the adequacy of the Residential Mortgage Lender and Originator to manage FinCEN’s anti-money laundering program and its compliance in filing Suspicious Activity Reports (SARs).
Review management’s commitment to implement effective monitoring and reporting systems.