Depending on the scope of your business, (e.g.; lender, non-delegated or broker) you have different audits required. Customize the list we provide in your Compliance Manager Duties.
We have a suggested training calendar in the compliance manual. We don't recommend doing all training all at once.
Each state may have its own specific requirements, and each investor/agency has it's own documents, but here are the big ones.
We see a lot of bad policies and procedures. Why do they keep getting recirculated?
Broker or Lender - You should deliver the Privacy Notice BEFORE you share any information with your customer.
You cannot change LO compensation when any change is a proxy for loan terms, except when it is in the borrower's best interests.
Depends on the size of your business and whether YOU are providing the credit decision
While state specific disclosures differ from state to state, the standard pack of disclosures for EVERY loan depends on the loan type.
To comply with AML/BSA rules, the company's compliance officer must be prepared to file a Suspicious Activity Report.
We are happy to re-create your order, but if you've lost your documents due to computer failure, that is a HUGE red flag.
Can a broker or lender charge a borrower a fee for a credit rescore? Can the fee on the LE and CD be updated for a rescore?
Step one of the AML/BSA Independent Audit is to validate that the BSA Officer has the ability to access the BSA E-Filing Platform
What do I have to do when an application doesn't go anywhere?
What documents do we keep after a file closes? Can I just get a printout from my lender?
AML Compliance requires 4 things - 1.) AML Officer (that's you), 2.) Compliance Plan (your 1-70 BSA AML Plan) 3.) Annual Training, and 4.) Independent Review
These are notoriously egregious sources of consumer abuse. Generally, be very careful with any engagement with them.
Managers must take the same quizzes as employees, but they also have to take additional training. We have an extensive library of compliance manager training on YouTube. Here's how to document online training video completion on YouTube.
I recently discovered your article published in the subject of dual capacity where the loan originator acts as the Realtor also. I can not find where this is permissible in the state of Ohio. Do you have any subject matter that would confirm this is allowed in the state or be able to direct me to a resource to confirm this please ?
The problem arises when you try to act in both roles in the same transaction and "double-dip." Now you have a conflict of interest.
Many regulations adjust caps and thresholds based on the current value of money, which changes with interest rates and inflation. Here are some of the most common thresholds.