When a regulator requests documents, don't just send them everything you have and let them figure out what it is. Try to tailor the response in a way that matches the request.
- Figure out what they are asking for. Even when they say "all policies and procedures," they usually follow that with "to include Quality Control, TRID, ID Theft Red Flags, and AML."
- Only send those by
- Printing those sections from the manual - here's a cheat sheet of where those are located
- Naming them according to what the regulator requested; e.g.; 1-a AML Plan, etc.
Understand what modules you have
Most customers purchase a compliance package. The package contains 3 modules:
1 - QC, which is your loan process - effectively your operations manual
2 - Compliance - which is the compliance manager's handbook. Questions about compliance can be answered from this.
2-9 Information Security - which is everything relating to keeping customer information secure
Understand what is in each module
Each module is in a folder and contains two components -
1 - the actual document which is a policy and procedure
2 - a subfolder which contains forms you can use.
When submitting to a regulator, you only give them what they ask for. The packages are your internal documentation, so only send the policies they specifically request. Sending them everything without identifying what they requested tells the regulator you don't know or understand the policies, which damages your reputation with the regulator, and our position as a provider of compliance support - for EVERYONE who uses our product. We are here to help, so let us know if you are unsure what to provide.
We understand that this is a lot of information. To make this a little more digestible, we have provided a Policy in Practice (PIP) for most of these larger items regularly requested by the regulators. These QuickNotes for how to comply can be provided to the regulator if they feel what you present is too detailed. Remember, the manuals are like a "User Guide" for the mortgage industry and are meant to be used as a reference.