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 • Company’s training is satisfactory. Compliance professionals have access to training necessary to administer a compliance program tailored to the Company’s risk profile, business strategy, and operations. • Compliance training is comprehensive, timely, and specifically tailored to the responsibilities of the staff receiving it. Page 3 of 3 Outline for drafting AFR w riteups • Brief discussion of company policies and procedures and the company’s practices. I n general, AFR writeups are around 1-3 paragraphs long. • Please note: Writeups should sufficiently describe any issues noted, but not include superfluous information so that it increases the length of the ROE unnecessarily. o Do they have a policy and procedure? o Is it sufficient and compliant? o Are they following it? o Are there any significant issues in this area or one - offs?  If so, what is management’s attitude towards the issues?  Remediated?  Caught by examiners or the company?  Fixed, in the process of being fixed, or ignored? • Any violations, recommendations, observations, and/or MRAs to address? AFR w riting s amples  Complaints • Company’s consumer complaint response is deficient. • Company’s policies and procedures do not outline the responsibilities of branch employees for reporting a complaint when the complaint is handled solely within the branch. • Company is unable to ensure all complaints, regardless of where submitted, are appropriately recorded, and categorized. o Recommendation: Ensure consumer complaints, regardless of where submitted, are appropriately recorded, and categorized.  Policies and Procedures • Company’s policies and procedures are deficient. Examiners found policies and procedures did not adequately address compliance risk associated with mortgage origination products, services, and activities of the Company, resulting in violations of Regulation Z. • Policies and procedures contained gaps, which resulted in an inadequate design of the loan origination system, documentation practices specific to changes in circumstance, and understanding of the mortgage origination disclosure requirements. • Examiners found that the Compliance Department did not review or approve business line policies, which led to incomplete coverage of the Company’s compliance responsibilities. • Recommendation: Implement a centralized system for the creation, tracking, and maintenance of policies and procedures to ensure they are current and accessible for employees in their day-to- day activities.  Training