Compliance
Monthly & Hourly 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 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 Audit Scope: Comprehensive within Compliance Management System.
- Baseline Features:
- Full business, GSE-compliant, compliance review
- End-to-end evaluation from these levels:
- transactional,
- organizational,
- third-parties.
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.
- 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
Our Risk Assessment and Gap Analysis evaluates for the following results:
- 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.
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.
Already in a compliance quagmire? We can extricate you with expert, practical advice and solid mortgage servicing compliance policies, procedures, practices, and internal controls that regulators trust, respect, and require.
Master Servicerr Oversight
Master Servicer Oversight includes 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
Servicing Tune-up®
Our Compliance Tune-up is a unique, expeditious, cost-effective auditing experience that targets products, services, departments, functions, regulatory compliance, and statutory-based procedures.
The Servicing Tune-up covers virtually all departments, functions, and regulations associated with the mortgage servicing department and its functions.
Purpose: Targeted Audit, Self-Identification, Risk Assessment
Line of Defense: Second – Risk Management and Compliance Functions
Process: Similar to audits by a federal agency or state banking department.
Quality Control
Quality Control
Compliance is crucial when it comes to Mortgage Servicing. Our experienced team of servicing auditors examine your individual servicing records to ensure overall adherence to applicable statutory and regulatory requirements from agencies such as Fannie Mae, Freddie Mac, FHA, VA, CFPB, State Compliance and more.
Our servicing audit process utilizes loan level reviews such as Foreclosure, Loss Mitigation, ARM Adjustments and Servicing Transfers to gauge compliance with regulatory requirements.
Targeted Audits
To make certain that audit results will be statistically valid, over two dozen key servicing functions can be targeted during the selection process.
Each of these targeted areas are referred to as an Area of Inquiry (AOI). We review and analyze all impacted AOIs applicable to the subject servicing portfolio. AOIs incorporated into a typical mortgage servicing audit include, but are not limited to:
- ARM Adjustments and Conversions
- Bankruptcy Requirements
- Claims
- Collections/Default
- Escrow/Tax/Insurance
- Foreclosure
- Loss Mitigation Efforts
- Property Management
- Paid in Full
- Payment Processing
- Servicing Transfers
State-Specific Servicing QC
Mortgage Loan Servicing: State-specific requirements as they pertain to the servicing of mortgage loans can be included in the servicing audit testing scripts.
Foreclosure Rules: Approximately 5,000 state-specific questions are included to address all pertinent aspects of the residential mortgage foreclosure process. A thorough monitoring of state-specific foreclosure requirements has never been easier.
Quality Control Plan - Servicing
Our Quality Control Plan establishes the policy of monitoring loan servicing activities to ensure that all FHA, VA, USDA, and conventional loans that are originated meet the standards of the Company and those of its insurers, investors, regulatory agencies, GSEs, and HUD.
To accomplish this Plan’s objective, this Plan provides formal practices and procedures for mortgage loan servicing quality control, as follows:
A. Accurately monitors all loan servicing functions, processes, documents, events, and the compliance and legalities in connection therewith;
B. Assures that mortgages are serviced to:
1. Conform to Company policy and procedures,
2. Comply with FHA, VA, USDA, insurer/guarantor requirements, and
3. Meet specific investor requirements; and
C. Evaluates and monitors the overall quality of loan servicing.