2025 Regulatory Summit

9/3/2025

Major Risk Factors: Unclear underwriting standards Loan officer deviations Not tracking deviations Ineffective or non-existent monitoring Risk Mitigation: Clearly written and understood underwriting standards Deviations to policy are the “exception” not the “norm” Secondary underwriting reviews Part of your CMS monitoring

Underwriting

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One of the greatest risks and easiest to track Rate sheet – not only having one but using it Consistency Exceptions – Are you tracking AND what are you doing with the info? – more on that in a moment Discretion should be controlled and monitored Examples: Across-the-board Consumer Pricing Wild West Consumer Pricing

Pricing

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