Intro to Becoming an MMC EIC eBook
CONFIDENTIAL
Instructions for D rafting Finding s and AFR Writ eups on MMC Multistate Mortgage Examinations
SES Portal Resources: Conducting a Supervisory Activity / Reviewing Information Request Responses / Reviewing Loan Request Responses / Working Procedures / Adding Findings / Matters Requiring Attention / Marking an AFR Complete / Reviewing the Report As a general rule of thumb, an MRA should be added to a finding when a participating agency and/or exam team requires the c ompany to address the finding within a specified timeframe after the exam closes (e.g., within 90 days). The MRA functionality in SES allows examiners to communicate with a company and keep a finding open until the MRA is satisfied. The finding functionality does not allow for th ese back -and- forth communications once an exam is closed. Page 1 of 3 This guidance is intended to instruct examiners on where to upload findings and AFR writeups in SES, outline the types of findings, determine when it may be appropriate to add a Matter Requiring Attention (MRA) to a finding, and provide tips for drafting clear and concise findings and AFR writeups. All examiners participating in MMC exams are responsible for drafting clear and concise state and federal findings for the Report of Examination (ROE). State and federal findings are included in the ROE under the Violations of Law and Consumer Harm component. All Area for Review (AFR) owners and contributors are responsible for providing clear and concise AFR wri teups for the ROE. As with findings, the AFR wri teups are intended to summarize all information reviewed for each AFR and address any violations, issues, or concerns identified during th at review . All AFR writ eups will be included in the appropriate components of the RO E. These include : 1. Board Oversight and Management 4. Information Technology and Cybersecurity 2. Compliance Program Financial Condition 5. Violations of Law and Consumer Harm 3. Financial Condition Adding Findings • All state and federal findings should be added to the Findings section in the supervisory activity in SES. Click here for instructions on adding and updating findings. • SES is the system of record for all MMC exams so m ake sure all supporting documentation, including any work papers used, are uploaded to the supervisory activity in the appropriate section. • If a finding is tied to specific loan request s , make sure to associate those loan requests to the finding. Click here for instructions on associating loans to a finding. • If a finding includes a n MRA, make sure to associate the MRA to the finding. Click here for instructions on adding an MRA to a finding. Adding AFR w riteups • All AFR writeups should be uploaded to the Report Commentary section of the supervisory activity in SES. It is recommended that you upload a Word document that includes the AFR writeup. Click here for instructions on adding report commentary. • Make sure to select the appropriate AFR and upload any supporting documentation. Types of Findings and w hen to a dd MRAs The MMC understands that agencies vary in how they address findings on mortgage exam s . Therefore, it is up to each participating agency (in consultation with the EIC if needed ) to determine the appropriate type of finding and whether to include an MRA. This guidance was created using the definitions outlined in the SES General Policy.
Made with FlippingBook Online newsletter creator