Lenders Compliance Group®
Creating a Culture of Compliance®
MEMBER OF NATIONAL ORGANIZATIONS
ABA | MBA | NAMB | AARMR | MISMO | ARMCP | ALTA | IIA | ACAMS | MERSCORP
SCG Solutions
Continuous Compliance™
We provide guidance, audits, due diligence reviews, and examination preparation, for transactional matters involving residential mortgage servicing.
We also assist clients with proactive and remedial efforts to enhance servicing compliance policies, procedures, practices and internal controls, including risk assessments and preparation and review of policies and procedures.
Low Monthly Flat Fee
On-going Compliance Support
Supervised by Directors
Subject Matter Experts
Unlimited Questions
Most Policy Documents
Secure Record Storage
Dedicated Team
Internal Audits
Internal auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization’s operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes.
- Internal Audits, known by regulators as Third Line of Defense.
- Internal Audit Scope: Comprehensive within Compliance Management System.
- Our Internal Audit:
- Full business, GSE-compliant, compliance review
- End-to-end evaluation from these levels:
- transactional,
- organizational,
- third-parties, and
- Findings:
- Identify potential risks and violations
- Offer opportunity to remediate
- Provide guidance to mitigate risk
- Reveal risk profile
- Risk Rating
Risk Appetite Statement
- Risk Appetite Statement is the amount and type of risk that an organization is willing to accept to meet its strategic objectives. This includes reference to both the organization’s risk appetite as well as its risk
- Risk Appetite is much more than a sophisticated Key Performance Indicator (KPI) System for risk management.
- Risk Appetite the core instrument for better aligning overall corporate strategy, capital allocation, and risk.
- Regulators, rating agencies, and professional investors request banks, non-banks and other financial institutions to advance their risk management practices to include risk appetite. A comprehensive Risk Appetite framework is the cornerstone of solid risk management architecture.
Risk Assessment & Gap Analysis
COMPREHENSIVE RISK ASSESSMENTS AND GAP ANALYSIS
- Inherent Risk is the level of risk present for products, services and activities if the organization does nothing to prevent or control it.
- Risk Controls are the policies, processes and procedures in place to mitigate and control the risk. An internal evaluation of the effectiveness of those policies, processes and procedures.
- Residual Risk is the gap between Inherent Risk and Risk Controls, identifying the areas for which compliance efforts should be focused.
- Egregious Risk is serious risk that is either unknown, unmitigated, not remediated, or all of these combined.
- Results Scenario # 1: Full Risk Assessments and Gap Analysis services, utilizing an approach that identifies the major inherent risks within the Lines of Business and that factor in any internal processes and practices which control or mitigate those risks.
- Results Scenario # 2: Alternatively, the results of this type of assessment may reveal internal processes and practices that may not effectively control any of the risks at all.
- Either Scenario: This type of review highlights any risk(s) present and/or remaining, whether inherent risks, residual risks, or previously unidentified egregious risk.
Servicer Quality Assurance
Our Quality Assurance Review is an independent audit and due diligence procedure that concentrates on various functional aspects of the servicer or subservicer. Furthermore, we can customize the review to conform to specific compliance needs.
Quality Assurance Reviews include, but may not be limited to:
- Structural Review
Ascertains that the servicer or subservicer has legal authority to operate in the client’s market, is a servicer or subservicer in good standing, and has adequate corporate structure and capacity to enter into a servicer or subservicer agreement.
- Financial Review
Determines the servicer’s or subservicer’s financial stability, financial controls, and capacity to enter into and continue a servicer or subservicer agreement.
- Operational Review
Verifies the servicer’s or subservicer’s operational compliance with investors’ requirements, loan performance metrics, and demonstrates the capability to provide quality service to both mortgagors and investors.
- Default Management
Evaluates default procedures and loss mitigation strategies, including default valuations, REO asset management and disposition, REO title, foreclosure title, short sales, and default workflow.
- Technology
Assesses origination workflow platform and integrity analyses of the loan origination system, technology licensing, appraisal reporting, collateral valuations, title insurance, insured and non-insured title reports, closing and escrow accounts, interim servicing, user interface, and normative report functions.
Servicing Compliance Audits
- Regulatory compliance reviews that satisfy “enhanced monitoring”.
- Audits that not only takes all GSE guidance into account but are very specific to the actual federal and state regulatory requirements for governance over each process within the Lines of Business.
- Multiple years and extensive experience involving all federal, state, and GSE regulatory mandates.
- Lines of Business and Oversight audits, utilizing the same process used by examining regulators.
- On-site and Off-site Reviews: become aware of compliance issues or violations before the regulators do!
Strategic Initiatives
By addressing compliance issues up front, at the planning stage, we can help you avoid costly mistakes and regulatory missteps well before your investment dollars are irrevocably committed. And, should you find yourself already in a compliance quagmire, we can help to extricate you with expert, practical advice and solid loan origination and mortgage servicing compliance policies, procedures, practices, and internal controls that regulators trust, respect, and require.
Master Servicer / Subservicer Oversight
Master Servicer / Sub-Servicer Oversight services include all components required by federal and state regulators, such as:
- Loan Servicing Due Diligence and Oversight practices (full business, end-to-end)
- Evaluation of the business structure
- Business Processes
- Vendors Management
- Servicing Documentation
- Servicing Performance
- Servicing Execution