Intro to Becoming an MMC EIC eBook

Introduction to Becoming an MMC EIC

February 18-20, 2025 Live Virtual

@ www.csbs.org ♦ @csbsnews

CONFERENCE OF STATE BANK SUPERVISORS 1300 I Street NW / Suite 700 / Washington, DC 20005 / (202) 296-2840

February 18-20, 2025 Introduction to Becoming an MMC EIC Live Virtual

ATTENDEES Indiana Department of Financial Institutions Shipman, Collin

cshipman@dfi.in.gov

Iowa Division of Banking Lander, Angelyn

angelyn.lander@idob.state.ia.us

Kansas Office of the State Bank Commissioner Freeman, Jennifer

jennifer.freeman@osbckansas.org dylan.page@osbckansas.org taryn.thomas@osbckansas.org

Page, Dylan

Thomas, Taryn

Maine Bureau of Consumer Credit Protection Kenney, Rhonda

rhonda.kenney@maine.gov

Maryland Department of Labor Office of Financial Regulation Wyngarden, John

john.wyngarden@maryland.gov

Michigan Department of Insurance and Financial Services Grove, Kara

grovek@michigan.gov

Missouri Division of Finance Askeland, Paul

paul.askeland@dof.mo.gov

Nebraska Department of Banking and Finance Dittman, Grant

grant.dittman@nebraska.gov

New York State Department of Financial Services Hollingsworth, Erselyne

erselyne.hollingsworth@dfs.ny.gov

Ku, Wesley

wesley.ku@dfs.ny.gov

Oyewumi, Albert

albert.oyewumi@dfs.ny.gov ninad.shah@dfs.ny.gov

Shah, Ninad

North Carolina Office of the Commissioner of Banks Bishop, Christy

cbishop@nccob.gov sgarfield@nccob.gov

Garfield, Sarah

Ohio Division of Financial Institutions Widay, Sheila

sheila.widay@com.ohio.gov

Oregon Division of Financial Regulation Hattan, Tim

tim.j.hattan@dcbs.oregon.gov rebeca.meixueiro@dcbs.oregon.gov

Meixueiro, Rebeca

Washington State Department of Financial Institutions Chavez-Rios, Jennifer

jennifer.chavez-rios@dfi.wa.gov

INSTRUCTORS Idaho Department of Finance Kline, Daniel

daniel.kline@finance.idaho.gov

Maryland Office of the Commissioner of Financial Regulation Mainolfi, Matt

matthew.mainolfi@maryland.gov

Washington State Department of Financial Institutions Monson, Jacob

jacob.monson@dfi.wa.gov lindsay.stenger@dfi.wa.gov

Stenger, Lindsay

CSBS STAFF Richardson, Amy

arichardson@csbs.org

Introduction to Becoming an MMC EIC Live Virtual February 18-20, 2025

Tuesday, February 18, 2025 1:00 pm – 2:00 pm

Introduction & Pre-Course Review

Break

2:00 pm – 2:10 pm

MMC EIC - What You Need to Know

2:10 pm – 3:00 pm

Break

3:00 pm – 3:10 pm

MMC EIC - What You Need to Know

3:10 pm – 4:00 pm

Wednesday, February 19, 2025 1:00 pm – 1:10 pm

Prior Day Review

MMC EIC - What You Need to Know

1:10 pm – 2:00 pm

Break

2:00 pm – 2:10 pm

MMC EIC - What You Need to Know & Writing the Report of Examination (ROE)

2:10 pm – 3:00 pm

Break

3:00 pm – 3:10 pm

Writing the ROE

3:10 pm – 4:00 pm

Thursday, February 20, 2025 1:00 pm – 1:10 pm

Prior Day Review

How to Run an Effective Meeting

1:10 pm – 1:50 pm

Break

1:50 pm – 2:00 pm

How to Run an Effective Meeting

2:00 pm – 2:50 pm

Break

2:50 pm – 3:00 pm

Effective Meeting Activities

3:00 pm – 3:50 pm

Wrap Up & Conclusion

3:50 pm – 4:00 pm

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Introduction to Becoming an MMC EIC

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Welcome!  Please be ready to learn and engage with your peers.  Be camera ready and have your camera turned on.  Minimize distractions as best as possible (close out of email, put your phone on silent, etc.)

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Zoom Features

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Attendance Policy In order to receive a certificate of completion for a CSBS virtual training, an attendee may not miss more than 1 hour throughout the duration of the training. Attendees must also participate in all training activities including exercises, presentations, and assessments to receive the credit hours (CEHs) and certificate. If a certificate of completion is not important to you, you may continue in the training even if you no longer meet the attendance requirement.

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Introductions

NAME

AGENCY/STATE

FUN FACT

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Instructors

Supervising Examiner / Investigator Idaho Department of Finance Daniel Kline

Matt Mainolfi Financial Non-Depository Examiner Maryland Office of the Commissioner of Financial Regulation Jacob Monson Financial Examiner Field Supervisor Washington State Department of Financial Institutions

Chief Learning Officer Washington State Department of Financial Institutions Lindsay Stenger

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Learning Objectives

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Session Learning Objectives: 1. Review pre-course materials 2. Understand the MMC examination process

3.

Understand exam management roles & responsibilities of the assigned MMC EIC Discuss SES, including benefits, library, company communications & SES milestones

4.

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Pre-Course Review

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Key Points – Pre-Course

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Key Points – Pre-Course SES Video

Nationwide system connects agencies & companies

Standardizes supervisory process

Fosters collaboration amongst agencies

Safeguards sensitive information

Serves as the system of record for all MMC exams

Readily available risk-based data

Internal Use Only

Multistate Mortgage Committee (MMC)

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Multistate Mortgage Committee (MMC) Who is the MMC? • Responsible for coordinating supervision of nonbank multistate mortgage lenders & servicers • Establishing standards • Developing & enhancing training • Scheduling, coordinating & overseeing all MMC exams • Monitoring mortgage industry for risk • Disseminating supervisory matters to state system • Consists of 10 state regulators appointed by CSBS & AARMR Boards

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Multistate Mortgage Committee (MMC)

Allie Wessel (WI) Chair

Kevin Cuff (MA) Vice Chair

Ken Bublitz (WA)

Craig Christensen (IA)

Annette Deffenbaugh (NC)

Christine Brooks (MD)

Aaron Clifton (DC)

Brenda Fanning (WY)

Paul Rhoades (FL)

Sheila Oliver (CA)

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Multistate Mortgage Committee (MMC) What is the OCOE? • One Company, One Exam Protocol (Regulator-only website) • Encourages agencies to participate in (limit 10), leverage, or accept • Purpose is to implement a standardized mortgage exam process and to reduce regulatory burden • Overseen by NDSC and MMC • Sets forth roles and responsibilities of all participants including EIC • Defines the 12-month exam moratorium that begins on the onsite start date and requests that agencies avoid scheduling concurrent exams. • MMC is responsible for identifying and scheduling

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Multistate Mortgage Committee (MMC) What does the MMC do? • Schedules and administers multistate mortgage exams and has conducted 49 multistate exams since 2018, including 3 OCOEs (counting the 2021 OCOE Pilot) • Works closely with the Risk Profiling Group (RPG) to determine the multistate mortgage entities (MMEs) to examine each year • Beginning in 2025, all MMC exams will be designated as OCOEs • Works closely with Consumer Financial Protection Bureau (CFPB) to conduct 2-3 coordinated exams annually • Conducts a minimum of 10 OCOEs annually

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Multistate Mortgage Committee (MMC) How is it done? • MMC multistate exam schedule shared with all state agency mortgage contacts each November via an online survey • Survey informs state system of upcoming exams & requests participation, including interest in leading as the EIC or SPOC • Any agency can volunteer to lead an MMC exam • Beginning 2023, MMC limits participation to 10 state agencies per exam • Limiting participants encourages agencies to accept or leverage results & reduces regulatory burden of the MME being examined

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Multistate Mortgage Committee (MMC) Training: • To encourage leadership participation on MMC exams & broaden the pool & expertise of mortgage examiners capable of leading these exams, the MMC introduced this training in November 2021 • Training provides mortgage examiners an understanding of the MMC exam process & the management role & responsibilities of the EIC

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Multistate Mortgage Committee (MMC) MMC Efforts: • Continuously works to improve multistate supervisory & exam process • Recent projects include implementing the Mortgage OCOE Protocol, revising the MMC Mortgage Examination Manual, condensing the MMC Report of Examination, & developing uniform mortgage exam programs & standards for all single state & multistate exams conducted through SES • Goal is to transform a 50-state supervisory system into a nationwide, networked system using common policies, practice & standards to prioritize exams based on risk & resource availability

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Multistate Mortgage Committee (MMC) How is the OCOE EIC Chosen? • MMC is responsible for selection of lead state agency (must participate) who then assigns the EIC • EIC role is the most significant role on an OCOE • Must be a skilled mortgage examiner with multiple years of experience • Must have active SES user account and experience with SES • Expectation is each state agency should commit to EIC or SPOC at least every third year • MMC will track agency involvement to ensure active participation

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MMC EIC Statistics • Of the 52 agencies that have participated in at least one MMC exam since 2018, 24 of the agencies have contributed as an EIC and/or SPOC and only 18 have contributed as EIC. • Benefits of serving as an EIC include learning and using leadership and project management skills and expanding your visibility as a leader in the state system.

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Multistate Mortgage Committee (MMC) MMC Identifies OCOE Companies Annually October

OCOEs closed and accepting states notified

MMC Schedules OCOEs for the following year

OCOE Lifecycle

Exam moratorium begins on the OCOE onsite start date

Agencies surveyed for participation interest

Have 2 months to express interest

Lead and participating state agencies identified

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Overview of SES

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Overview of SES

SES Benefits

Library

Company Enrollment/Communications

SES Milestones

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Benefits of SES - Regulators

Standardize Collaborate

Data

Safeguard

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Benefits of SES - Regulators

Standardize • Supervisory process

Collaborate

Data • Risk-based •Readily available

Safeguard

•Foster

• Sensitive

amongst state agencies

information

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Benefits of SES - Companies Consistency Reduced Burden

Assurance

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Benefits of SES - Companies

Consistency • Single system

Reduce Burden

Assurance • Ability to track

•Reduces

interaction with regulators

number of individual information requests

communications with regulators

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Overview of SES

SES Benefits

Library

Company Enrollment/Communications

SES Milestones

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SES Library

Areas for Review

Information Requests

SES

References Procedures

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SES Library

Areas for Review

Information Requests

SES

References Procedures

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SES Library

Information Requests

Areas for Review

SES

References Procedures

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SES Library

Areas for Review

Information Requests

SES

Procedures

References

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SES Library

Areas for Review

Information Requests

References Procedures SES

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SES Library Management

• Agency Specific Items • Standard Library Items • Core • Non-Core

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SES Library Management

Agency Specific

Standard

1 2

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SES Library Management

Non Core

Core

1 2

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SES Library • Investigations: • C ore & non-core are not automatically added • State to Standard Match Report • Staff User & Staff Director manage the Library

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SES Exam Scope

• Initiating a Supervisory Activity • Managing the Scope • Core AFRs for Residential

Mortgage: • Lender • Broker • Servicer • Master Servicer

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Overview of SES

SES Benefits

Library

Company Enrollment/Communications

SES Milestones

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Company Enrollment

Agency Sends SES Enrollment Request to Company

Company Receives Email to Activate Okta Account

Company Logs into SES

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Company Communications

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Overview of SES

SES Benefits

Library

Company Enrollment/Communications

SES Milestones

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Overview of SES

SES Milestones

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SES Milestones

Pending

Scheduled

Planning

In-Flight

Drafting

Close-Out

Closed

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SES Milestones

If EIC holds Staff Director or Staff User role: • Initiate SA • Send SA for Review • Add SA Participants

Pending

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SES Milestones

• Define the Scope • Send Scope for Review (optional) • Add and/or update SA Participants

Scheduled

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SES Milestones

• Define the Plan • Send Plan for Review (optional) • Send IRs to Company • Send Loan Requests to Company

Planning

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SES Milestones

• Review Findings • Schedule Exit Meeting • Upload Report

In-Flight

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SES Milestones

• Assign Package Assembler • Add MRAs • Review/Send MRAs to Company

Drafting

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SES Milestones

• Review & Respond to MRAs • Close MRAs • Enter Close-Out Information • Mark Report Response Complete

Close Out

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SES Milestones

If EIC holds Staff Director or Staff User role: • Close & Lock the SA

Closed

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SES Demo

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Questions

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How to Coordinate an MMC Examination

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What you need to know: • Participants

• Communication • Overview of SES • Examination Process • Timing / Schedule

• Resources • Technology

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Participants

Teamwork makes the dream work.

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Participants

MMC EIC

COMPANY

SPOC

STATES

MMC

CSBS

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Participants

• Project Manager • Facilitator • Should not lead a

complex subcommittee

MMC EIC (you!)

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Participants

• Make exam run as smoothly & efficient as possible for: • State examiners • Company • Ensure: • Path is clear • Expectations are known

MMC EIC (you!)

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Participants

EIC Definition in SES: • Agency user role • Responsible for: • Scoping examinations

• Assigning examination tasks • Generating & finalizing ROE • May conduct examination tasks & document findings

MMC EIC (you!)

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Participants

Individual EIC Knowledge and Experience Utilize it!

MMC EIC (you!)

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Participants

MMC EIC

SPOC

COMPANY

MMC Liaison

STATES

CSBS

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Participants

Single Point of Contact (SPOC) for MMC EIC

SPOC

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Participants

• Mentor/Advisor • Liaison • Resource

• Participates in meetings • Reviews draft documents

SPOC

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Participants

MMC EIC

COMPANY

SPOC

MMC Liaison

STATES

CSBS

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Participants

MMC Liaison • Assigned to exam • Technical & examination support • Escalation of issues to MMC

MMC Liaison

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Participants

MMC EIC

COMPANY

SPOC

MMC Liaison

STATES

CSBS

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Participants

• CSBS Support Staff • Administrative & logistical support • Questions about: • Exam process • Technology • Assist with updates to MMC

CSBS

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Participants

MMC EIC

COMPANY

SPOC

MMC Liaison

STATES

CSBS

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Participants

State EIC • Primary contact • ROE:

• Write their State section • State-specific findings • Update State Management

STATES

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Participants

State Examiners • File reviewers • Subcommittee leads • Write section

STATES

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Participants

State Management • Reviews State section ROE • Require elements included/excluded

STATES

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Participants

MMC EIC

COMPANY

SPOC

MMC Liaison

STATES

CSBS

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Participants

Company Primary Contact: • Questions & requests • Scheduling • Coordinates meetings • Company Lead in SES • All exam-related communications & information

COMPANY

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Participants

Company Management: • Meetings during exam • Coordinated through

Company Primary Contact

COMPANY

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Communication

Conference Calls, Emails, Notes, Oh My!

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Communication

States

Company

MMC

Conference Call Tips

Meeting Notes Tips

CFPB

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Communication - States

Meetings

Conference Calls

Emails

SES

EIC

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Communication - States

State Examination System (SES) • Interactions here

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Communication - States

Email • Reminders • File structure path

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Communication - States

Conference Calls • Specific questions during roll call • Schedule around exam events • Take notes & post

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Communication - States

Conference Call Schedule Example

Mid-Week Check-Ins (on-site)

Weekly (pre-exam)

Week After On-Site

Introductory

Week Report Submissions Due

Company Response

Finalize Ratings

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Communication - States

Introductory Call: • Introductions • Ice breaker

• Loan file submission • Preliminary findings • Examiner participation

• Expectations of roles • Schedule / exam plan • SES & Box

• Summarize examiner profiles • Subcommittee assignments

Introductory

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Communication - States

Weekly: • New Findings • Due dates • MMC resources available • Soft Exit & subcommittee assignment meetings

Weekly (pre-exam)

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Communication - States

Mid-Week Check-Ins: • New Findings • Due dates • MMC template • Plan for soft Exit

Mid-Week Check-Ins (on-site)

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Communication - States

Week After On-Site: • Thank examiners • New findings • Final request & write-up deadlines • Template reminder • Due dates

Week After On-Site

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Communication - States

Week Report Submissions Due: • Any issues

• Template reminder • Write-up deadline

Week Report Submissions Due

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Communication - States

Finalize Ratings: • Thank examiners • Finalize ratings

• Issues or concerns with Report • Draft report review & approval

Finalize Ratings

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Communication - States

Company Response: • Discuss issues • Discuss insufficient responses & need to obtain additional response, or MRA in SES

Company Response

Internal Use Only

Communication - Company

Meetings

Phone Calls

Emails

SES

EIC

Internal Use Only

Communication - Company

Call Schedule Example

After Loans Received & IRs Start

After Loan Request Sent

Week Before On-Site

Introductory

Other Possible Calls

Week After On-Site

Exit

Internal Use Only

Communication - Company

Introductory Call: • Introductions

• Number of states • Schedule overview • On-Site week • Loan list provided • On-Site needs • Company questions • Thank company

Introductory

Internal Use Only

Communication - Company

After Loan Request Sent: • Issues with due dates • Schedule overview • On-Site week • Loan level request timing

After Loan Request Sent

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Communication - Company

After Loans Received & IRs Start: • How requests will work & are working • Finalize on-site week schedule & expectations

After Loans Received & IRs Start

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Communication - Company

Week Before On-Site: • Finalize schedule & expectations • Answer any Company questions • Handle any scheduling hiccups

Week Before On-Site

Internal Use Only

Communication - Company

Week After On-Site: • Thank Company • Discuss timelines • Overview of schedule • Answer Company questions

Week After On-Site

Internal Use Only

Communication - Company

Other Possible Calls: • Soft exit • Enforcement actions • Delays

Other Possible Calls

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Communication - Company

Exit Meeting: • Final exit with Company • Time zones

Exit

Internal Use Only

Communication – MMC, SPOC & CSBS

Phone Calls

Emails

SES

EIC

Internal Use Only

Communication

Tips for Conference Calls: • State your name • Roll call & introductions • Ask questions of each state individually • Remember to pause…. • Outline before call • Ask if you missed anyone or if anything else to add

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Communication

Tips for Meeting Notes: • Taken for each meeting • State Conference Calls • Note Taker for subcommittee meetings • Save notes on SES Interactions page

Internal Use Only

Communication - CFPB

Coordinated Exam Communication Schedule

Develop Communication Plan

Initial Company Meeting/Call

Scoping and Planning

Weekly Meetings (pre-exam)

Post Exam

Exam Week

Close-Out

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Examination Process

“The secret to getting ahead is getting started.”

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Examination Process

• Where do you start? • Where are you going? • How do you get there?

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Examination Process

Beginning • Requests On-Site Week

Report Writing

Ratings

MMC Review of Draft ROE

Final Exit & Final Report

Response Review

Closing the Exam

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Examination Process

Beginning: • MMC chooses Company • You are chosen as the EIC • You receive email notification (typically, 120 days before onsite start date) • Determine subcommittees with SPOC • Determine subcommittee leads • Ask States for initial information requests • Initial calls – Company, States • Send initial information requests to Company

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Examination Process

Requests: • Types: initial, loan, subcommittee, additional • State requests • Company responses • Ensure request process, file naming & structure is clear to both the States and the Company

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Examination Process

On-Site Week: • Introductory meeting/tour

• Subcommittee meetings (calls) • State check-in call mid-week • Soft Exit

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Examination Process

On-Site Week - Preparation: • Inform Company: number of examiners, equipment needed, weekly/daily arrival & department times • Subcommittee meeting schedule • Assign note takers to each meeting • Ask States to prepare meeting outline prior to on-site week

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Examination Process

Report Writing: • MMC Template • Provide States MMC Finding Template • Guidance for AFR Report Writing Comments (for AFR owners and contributors) • Compile state sections into Report – One Voice • ROE revisions – do not reformat template unless approved by MMC Liaison

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Examination Process

Ratings: • Use MMC Template ratings • Ask each State to record their preferred ratings(s) during their review of the Report • Discuss ratings as a group during State call • MMC determines final ratings

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Examination Process

MMC Review of Draft ROE: • Timing • Authority • MMC determines final ratings

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Examination Process

Final Exit & Final Report: • After approved by MMC, provide Final ROE & ROE Cover Letter to Company • Host Final Exit call with Company & States • Determine State assignments prior to call • Be prepared for questions • Most important attendees: Company main contact(s), MMC EIC & the SPOC

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Examination Process

Response Review: • Notify participating States • Request States review state-specific finding & subcommittee responses • Schedule call to discuss review process, next steps & deadline • Centralize questions with EIC for follow-up with Company • Once review is complete, EIC draft closing letter

Internal Use Only

Examination Process

Closing the Exam: • MMC Template closing letter • Notify CSBS Staff • Send thank you email to States & MMC Staff

Internal Use Only

Timing/Schedule

“A goal without a plan is just a wish.”

Internal Use Only

Timing/Schedule

Outline of Exam

Planning On-Site Week

Scheduling Meetings

EIC’s Time

Internal Use Only

Timing/Schedule

Outline of Exam • Use MMC EIC – SPOC Timeline to determine due dates • Use your own running excel calendar for exam team • Due dates need to be shared early and repeated often • Share EIC’s schedule (work schedule, leave, etc.)

Internal Use Only

Timing/Schedule

Planning On-Site Week • Understand State work hour expectations & time zones • Create schedule for week • Ensure Company representatives meet the needs of the subcommittee lead examiners • Plan 30-minute meetings with 30 minutes between each meeting • Allow for two rooms • Assign note taker to each meeting • Ensure expectations of meetings are clear & communicated to both States & Company

Internal Use Only

Timing/Schedule

Scheduling Meetings • Understand time zones & work schedules • Consistency for recurring meetings • If you don’t need an hour, don’t schedule an hour • Determine key participants

Internal Use Only

Timing/Schedule

EIC’s Time • Key to successful examination is MMC EIC is given TIME to be the EIC

• Communication and answering questions • Organization and scheduling meetings

Internal Use Only

Timing/Schedule MMC Exam Timeline – Prior to Exam Start

Request ISB/EP Form

EIC & SPOC Call Company

90

80

120

60

Exam Notification Letter

Exam Plan & IR Due Date

Internal Use Only

Timing/Schedule MMC Exam Timeline – Prior to Exam Start

Loan Files Due From Company

EIC Finalizes Onsite Week

45

30

14

7

EIC Reviews Exam Plan

EIC & SPOC Call States & Company

Internal Use Only

Timing/Schedule MMC Exam Timeline – Post Exam On-Site

EIC Finalizes and Uploads Initial Draft ROE

MMC ROE Preparation

1

21

45

States Submit Findings & Assignments

Internal Use Only

Timing/Schedule MMC Exam Timeline – Post Exam On-Site

EIC Finalizes ROE, Sends to Company

EIC Notification ROE is Ready for MMC

70

80

90

EIC Schedules a Final Exit Meeting With the Company

Internal Use Only

Timing/Schedule MMC Exam Timeline – Post Exam On-Site

Company Response Due

EIC Closes the Exam in SES

130

130

120

Accept/Reject Exam Response From Agencies

Internal Use Only

Resources

“All the resources we need are in the mind.”

Internal Use Only

Resources

Manual

Templates

Subcommittee Guidance

Contacts

Internal Use Only

Resources

Manual

Rating Information

Regulation Information

Internal Use Only

Resources

Templates

• MMC Uniform Exam Findings Template • MMC Origination or Servicing ROE Template • Letters • MMC Examination Plan

Internal Use Only

Resources Subcommittee Guidance

• MMC Compliance Management System Exam Procedures • Financial Condition Exam Procedures • MMC BSA – AML Program Examination Procedures • MMC Mortgage Examination Manual • Past Exams – request & make available at beginning of Exam • Ensure you have most current versions!

Internal Use Only

Resources

Contacts

SPOC • Exam procedures, timelines, expectations • Report writing/template • State accountability • Company conflicts

CSBS Staff • Exam procedures, timelines, expectations • Technology questions

Internal Use Only

Technology

“A computer will do what you tell it to do, but that may be much different from what you had in mind.”

Internal Use Only

Technology

Helpful Contacts & Resources

Encrypted Email

Technology Overview

File Organization

Internal Use Only

Technology

Technology Overview

External Software

SES

Box

Internal Use Only

Technology

• Plan file organization before files are received

• Organize files clearly, simply & consistently

File Organization

• Include file pathway when referencing documents in email or in call notes

• Always offer to help find documents

Internal Use Only

Technology

• Resource Portal • SES Call Center • RUG • CSBS Support Staff

Helpful Contacts & Resources

Internal Use Only

Technology

• All email communication

Encrypted Email

• Ensure States are aware of this at the beginning of the exam

• States may have different programs

Internal Use Only

Questions

Internal Use Only

Internal Use Only

Resources

• SES Portal • Understanding the Library • Taking Action on Your Exam Scheduling “To Do” List • Using Exam Scheduling • Company Enrollment in SES – How it Works • Enrolling a Company User for Exams or Complaints

Internal Use Only

Internal Use Only

Introduction to Becoming an MMC EIC Writing the ROE

Internal Use Only

Session Learning Objectives: 1. Apply critical thinking to develop better report content. 2. Discuss best practices for report writing. 3. Apply concepts to writing exercises.

Internal Use Only

Writing the Report of Examination (ROE)

Internal Use Only

Writing the ROE The ROE should provide a clear, concise, and objective evaluation of the examinee’s overall condition.

Internal Use Only

Writing the ROE The ROE is the principal vehicle used to communicate examination findings and need for corrective actions.

Internal Use Only

Writing the ROE

Communication is essential to the proper development of examination findings and overall conclusions.

Internal Use Only

Writing the ROE

Critical Thinking Relevant and accurate findings

Appropriate Content Information that is easily understandable

Appropriate Structure Information that is easily followed

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Structure

Structure should be logically, simply, and consistently arranged.

Internal Use Only

Structure Examination Purpose

Examination Scope Overall Summary/Component Sections Examination Findings – Expectations/Recommendations - Conclusions Violations of Law & Consumer Harm State/Federal Examination Finding - Recommendations Conclusion

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Content

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Content

• Be accurate • Reflect the appropriate tone • Provide explanation and support for findings

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Content

Do Not: • Make unsubstantiated assertions • Overwhelm the reader • Include unnecessary technical terms or jargon

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Content

Plan: • Before you write • Focus on points to include rather than

struggling with words

Internal Use Only

Content When first introducing an agency, acronym, or abbreviation, write out the full name followed by the abbreviation in parentheses. For Example: • The Consumer Financial Protection Bureau (CFPB) • Report of Examination (ROE) • North Carolina Commissioner of Banks (NCCOB)

Internal Use Only

Content Write your initial draft Wait a day or two before reading it over – fresh perspective Use spell check, then read your work If in doubt, look it up! Take pride in your writing; turn in your best possible work.

Internal Use Only

Content

Ask yourself: • Is the language within the ROE simple, nontechnical, and clear? • Can management understand the terms, concepts, and relationships? • Do paragraphs contain topic sentences that summarize the main idea? • Does each section have a lead paragraph which provides a summary and analysis? • Do the paragraphs that follow provide support, substantiate, and explain the analysis?

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Content

Ask yourself: • Do all sentences within each paragraph have both unity and coherence? • Are sentences sufficiently short and clear to allow readers to understand them? • Is the tone of the ROE appropriate in respect to the ratings assigned? • Does the report focus on the important issues identified by the examination team?

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Content

Ask yourself: • Is the level of detail sufficient to convince readers of the problem, but not so minute to hinder the message? • Has each section of the ROE been filled out? • Is each area identified in the scope addressed in the body of the ROE? • Will recommendations resolve issues?

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Content

Ask yourself: • Does the ROE establish the significance of the conditions? • Does the report provide a proper perspective of the strengths and weaknesses of the company? • Does the summary section provide the results of the examination findings and their significance without specific detail? • Do findings clearly identify the applicable state or federal law, rule, or regulation?

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Content

Ask yourself: • Are findings adequately developed? • Did you double-check facts, figures, and proper names?

• If information remains to be inserted at the last minute, highlight the omission prominently so that no one forgets.

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Resources • The Business Writer’s Handbook: http://www.grammarbook.com • SES Examinations and Investigations Resources for Agencies: https://portal.stateexaminationsystem.org/chapterMaps/c_agency_part _SA.html

• MMC Exam Resources: SES Library

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Exercise

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Introduction to Becoming an MMC EIC How to Run an Effective Meeting

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Session Learning Objectives: 1. Understand when it is necessary to hold meetings

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Session Learning Objectives: 2. Understand how to plan a meeting and create an agenda

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Session Learning Objectives: 3. Discuss best practices for running an effective meeting

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How to Run an Effective Meeting

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Agenda

• Meeting purpose • Is it necessary? • Logistics • Optics

• Planning • Preparing

• During the Meeting • Ending the Meeting • After the Meeting • Activities

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Purpose of the Meeting

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What is the purpose of the meeting? • Learn about the Company • Set goals or timelines

• Make decisions • Discuss findings • Clear up confusion

Have a clear objective.

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Examples Entrance Meeting: • Company & examiners • Meet & greet • Set exam expectations • Discuss general exam information

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Examples Exit Meeting: • Company & examiners • Review findings • Review matters of concern • Set timelines • Discuss possible enforcement action

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Is the Meeting Necessary?

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Confirm the Meeting Is Necessary Could the information be provided or received in another way? • E-mail • Telephone

• Memo • Letter • Portal

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Confirm the Meeting Is Necessary A common mistake is to schedule a meeting when it is not needed

• Sometimes a conversation would be sufficient and more appropriate

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Meeting Logistics

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Meeting Logistics

• On-site or Off-site • Time zones • Remote attendance option

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Meeting Optics

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Meeting Optics

• On time • Attire • Nonverbal communication • Eye contact • Face the group

• Facial expressions • Posture & gestures

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Planning for the Meeting

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Planning for the Meeting

• Agenda • Participants • Timing • Location

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Preparing for the Meeting

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Preparing for the Meeting

• Provide attendees agenda • Assign scribe • Distribute documents

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Preparing for the Meeting

• Prepare yourself • Questions • Information requests • Anticipate

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During the Meeting

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During the Meeting

Be Present • Bring pen & paper • Do not bring devices

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During the Meeting Be Engaged • Listen

• Be confident • Participation • Follow agenda

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During the Meeting Maintain Control • Items off topic • Disagreements • Meeting times

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During the Meeting Questions & Responses • Ask follow-up questions • Responses

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Ending the Meeting

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Ending the Meeting

• Questions • Action items

• Set expectations • Thank attendees

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After the Meeting

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After the Meeting

• Distribute documents • Distribute important notes • Action items

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Internal Use Only

Resources • business.com - 7 Powerful Tips for Highly Productive Online Meetings: https://www.business.com/articles/7-powerful-tips-for-highly-productive-online meetings/ • Forbes - 12 Tips For Making Your Virtual Meetings More Professional: https://www.forbes.com/sites/josephliu/2020/03/17/virtual-meeting tips/#5738bcfe7208

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Internal Use Only

Activities

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Mortgage One Company, One Exam Protocol May 2023

With the release of this Mortgage One Company, One Exam (OCOE) Protocol, state mortgage regulators are implementing a new approach to multi-state mortgage supervision. The Non-Depository Supervisory Committee (NDSC) and the Multi-state Mortgage Committee (MMC) oversee this Protocol. OCOE supervision is a key strategic initiative in advancing Networked Supervision among state regulators.

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Table of Contents Background and Purpose ..................................................................................................................... 3 Acronyms and Definitions .................................................................................................................... 3 Role of the MMC .................................................................................................................................. 5 OCOE Mortgage Company Identification .............................................................................................. 5 Mortgage Originators ...................................................................................................................... 6 Mortgage Servicers.......................................................................................................................... 6 Target Number of MMEs to Receive OMC Designation.................................................................. 6 Examination Scheduling ....................................................................................................................... 6 Maximum Number of Participating State Agencies ........................................................................ 7 Lead State Agency and Participating Agency Selection ......................................................................... 7 Examiner-in-Charge ......................................................................................................................... 8 EIC and SPOC Pool and Resources ................................................................................................... 9 Scope of Examinations ......................................................................................................................... 9 Examination Participation Parameters ................................................................................................. 9 No Concurrent Examinations.............................................................................................................. 10 Examination Moratorium ................................................................................................................... 10 Accepting and Leveraging Agencies .................................................................................................... 11 Accepting Agencies........................................................................................................................ 11 Leveraging Agencies ...................................................................................................................... 11 Non-OCOE Examinations .................................................................................................................... 11 OCOE Support .................................................................................................................................... 12

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Background and Purpose Significant growth in the nonbank mortgage market, specifically the volume of state licensed companies and mortgage loan originators 1 , has bolstered the need to develop an enhanced networked approach to mortgage supervision. The Mortgage One Company, One Exam (OCOE) Protocol (“Protocol”) is an approach to multi-state mortgage supervision that enables state agencies to increase coordination and share supervisory resources to minimize regulatory burden and overlap. The Conference of State Bank Supervisors (CSBS) Non-Depository Supervisory Committee (NDSC) 2 and the Multi state Mortgage Committee (MMC) 3 oversee this Protocol. Under the OCOE supervisory approach, all state agencies are encouraged to participate in or accept the result of one multi-state exam for one company. The end goal is to empower the state system to operate a single, nationwide, networked, supervisory system using common policies, practices, and standards to prioritize examinations based on risk and resource availability.

Overview of the recurring process established by this Protocol:

Acronyms and Definitions

AARMR

American Association of Residential Mortgage Regulators

AFR CFPB CMS

Area for Review

Consumer Financial Protection Bureau Compliance Management System

EIC

Examiner-in-Charge

FFIEC

Federal Financial Institutions Examination Council

IR

Information Request

LEF

Lending Examination Format Multi-state Mortgage Committee Multi-state Mortgage Entity

MMC MME NDSC NMLS OCOE OMC

Non-Depository Supervisory Committee Nationwide Multi-state Licensing System

One Company, One Exam OCOE Mortgage Company

1 SRR Annual Reports available on the NMLS Resource Center show the volume of licensed companies and individuals over the last 10 years. 2 The NDSC is a standing committee of the CSBS Board established to provide commissioner level oversight of nonbank supervision and a reporting mechanism to the Board. 3 The MMC is established under the CSBS/AARMR Nationwide Cooperative Agreement for Mortgage Supervision and consists of ten representatives, five of which are appointed by CSBS and five of which are appointed by the American Association of Residential Mortgage Regulators (AARMR).

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PSC ROE RPG SCC SES

Performance Standards Committee

Report of Examination Risk Profiling Group

State Coordinating Committee State Examination System

SPOC

Single Point-of-Contact

Accepting State Agency – An agency that accepts an OCOE without further review of the company and in lieu of conducting its own examination. Area for Review – A review topic used to define the scope of an examination or investigation. AFRs are also used to categorize SES library items. 4 Business Activities – Generic, non-legal definitions of financial services activities that reasonably describe the activity a company engages in. No activity can be covered by more than one definition. 5 Coordinated Examination – A multi-state examination conducted jointly between state regulators and the CFPB. The MMC schedules coordinated examinations annually in coordination with the SCC and CFPB. 6 Examination Moratorium or Moratorium – 12-month pause on the review of business activities and AFR(s) examined during the OCOE. The 12-month Moratorium begins on the OCOE onsite start date. The Moratorium provides regulatory relief to the company without overly constraining an agency’s ability to supervise the company. The application and length of the Moratorium is dependent on exam ratings and any other factors that may require immediate regulatory supervision. These factors can include company financial deterioration, consumer complaints, state or federal actions, etc. Examination Scope – Mortgage origination AFR(s) or mortgage servicing AFR(s). Lead State Agency – A participating state agency on an OCOE that designates an experienced examiner to serve as the EIC on the examination. The MMC is responsible for selecting the lead state agency who assigns the EIC. Leveraging State Agency – An agency that utilizes the results of an OCOE to conduct its own targeted examination once the Examination Moratorium ends. Moratorium State Agency – An agency that does not participate or accept the results of an OCOE and adheres to the Examination Moratorium. Mortgage Examination Standards – Uniform set of AFRs, IRs, and exam procedures used on OCOEs. The standards are established by the MMC and approved by the NDSC. The use of the standards ensures that an OCOE meets the minimum examination standards agreed upon by all agencies. 7 Non-conforming State Agency – An agency that does not adhere to the 12-month Examination Moratorium by conducting its own examination and reviewing one or more of the AFRs reviewed as part of the OCOE.

4 Definition of Area for Review as provided by the SES Policy Guide. 5 Definition of Business Activities as provided by the NMLS Policy Guidebook. 6 See 2013 CFPB-State Supervisory Coordination Framework.

7 The Mortgage Examination Standards reviewed by all state mortgage regulatory agencies during a Regulator-only Comment period. The Mortgage Examination Standards incorporate state-specific requirements received from agencies during the 2023 comment period.

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