Louisiana Department of Banking Mortgage Examination Requirements

Policies and Procedures Manual: The Louisiana Department of Banking requires licensees to provide a comprehensive Policies and Procedures Manual, which includes:

• Employee/Originator Training: Detailed policies on training are found in the Quality Control Plan, Section 1-70 (AML Training Program)​(1-A Broker MiniC QC Pla…).

• Employee Handbook: Outlines for employee responsibilities and company policies are included in the Compliance Module, Section 2-72 (New Hire and Employee Procedures)​(2.0 Compliance Module).

• Disaster Recovery Plan: Located in the IT Security GLB Safeguarding Plan, Section 2-97 (Disaster Recovery and Business Continuity)​(2-9 IT Security GLB Saf…).

• BSA/AML: The entire BSA/AML program is outlined in the Quality Control Plan, Section 1-70, which covers AML procedures, SAR filing, risk assessments, and red flags specifically related to mortgage operations​(1-A Broker MiniC QC Pla…).

• Third-party Contractor Oversight: Policies for third-party management are found in the IT Security Plan, Section 2-96 (Vendor IT Security Risk Assessment)​(2-9 IT Security GLB Saf…).

• Origination and Servicing Policies and Procedures: Detailed policies for loan origination and servicing are covered in the Compliance Module, Sections 2-31 and 2-40 (Loan Origination, Servicing, and Fair Lending)​(2.0 Compliance Module).

• Ability to Repay: Compliance requirements are outlined in the Compliance Module, Section 2-37 (Ability to Repay)​(2.0 Compliance Module).

• Social Media Use and Advertising: Guidelines on social media practices and advertising are specified in the Compliance Module, Section 2-34 (Social Media and Advertising Policy)​(2.0 Compliance Module).

• Elder Financial Abuse: Policies addressing elder financial abuse are covered under Section 2-35-26 (UDAAP - Elder Abuse)​(2.0 Compliance Module).

• Complaint Resolution: Procedures for managing complaints are detailed in the Compliance Module, Section 2-80 (Complaint Resolution)​(2.0 Compliance Module).

• Consumer Protection: UDAAP practices and various consumer protection guidelines are located in the Compliance Module, Section 2-35 (Unfair and Deceptive Acts)​(2.0 Compliance Module).

• Data Security: Policies on data protection and information security are in the IT Security Plan, Section 2-90 (Information/Cyber Security Plan)​(2-9 IT Security GLB Saf…).

BSA, Cyber Security, and Data Protection Requirements:

• AML and SAR Program: The structure and management of the AML and SAR program, including the compliance manager's role and training schedules, are detailed in the Quality Control Plan, Section 1-70. This section includes guidelines on customer due diligence, reporting procedures, red flags, and specific risk assessments for high-risk activities​(1-A Broker MiniC QC Pla…).

• Independent 3rd Party Review/Audit: Information on independent third-party audits and contact details are documented in the Quality Control Plan, Section 1-70-6 (AML Audit Process)​(1-A Broker MiniC QC Pla…).

• Contingency Plan for Data Breach: The data breach response and incident handling policy are located in the IT Security Plan, Section 2-92 (Data Breach/Incident Response Policy)​(2-9 IT Security GLB Saf…).

This revised response integrates the relevant sections from the Quality Control Plan to ensure comprehensive compliance with the Louisiana Department of Banking's requirements for mortgage examinations.