Intro to Becoming an MMC EIC eBook

CONFIDENTIAL

Instructions for D rafting Finding s and AFR Writ eups on MMC Multistate Mortgage Examinations

Finding A finding is an issue identified during an examination that will be included in the ROE. The C ompany will have the opportunity to respond to all findings. A finding can be placed in one of three (3) categories in SES: How t o Determine “Findings” Category

A finding that is a transgression of a law, regulation, rule, or administrative code. This will be included in the ROE as a finding in Violations of Law and Consumer Harm under “Federal Regulatory Compliance” or “State Regulatory Compliance.” All examiners must provide: • A clear writeup addressing the violation, using the format MMC format. • All steps the Company must take to correct the violation. • Consider a dding an MRA if the corrective action will extend past the exam closing date. A finding that is medium to high risk, but not a transgression of a law or regulation. The Company should make changes to improve its overall risk management or to comply with internal policies and procedures. This w ill be included in the ROE as an “internal routine and control exception.” All examiners must provide: • A clear writeup addressing the observation, using the MMC format . • All steps the Company should take to mitigate the risks. A finding that is generally lower risk but still an issue that the r egulator wants the Company to be aware of. If the Company implements the suggestion(s) outlined, the Company will improve its compliance or risk management posture. This will be included in the report as an “internal routine and control exception.” All examiners mu s t provide: • A clear writeup of the risks with s uggestions on steps the Company can take to improve its compliance and risk posture.

Violation

Observation

Recommendation

Writing ti ps • All findings and AFR writeups should clearly present conclusions that are well supported by facts obtained during the exam. Since SES is the system of record for all MMC exam s , all documentation supporting each finding and AFR should be uploaded to the appropriate finding, AFR, or Report Commentary writeup. • All findings and AFR writeups should be clear, concise, convincing, and accurate. The writeups should include information and statements that support the findings, violations, issues, or concerns addressed. Do not include irrelevant information or summarize information the company provided . • Use simple, non - technical language that can be understood by all audiences. Avoid jargon unless you know the company will understand it or there are no simpler terms to describe something. • State and federal findings that relate to any AFR should also be referenced in the AFR writeup. • All findings and AFR writeups should support and validate the exam ratings.

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

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