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.

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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.

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

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.

• 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.

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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.

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

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