Intro to Mortgage Origination Examinations Training - July 2025

4. Appraiser engagement – use of appraisal management companies 5. Transfer of appraisals 6. Referrals of appraisal misconduct 7. Appraisal review/quality control 8. Training of staff on appraiser independence requirements

12 C.F.R. 1026 – Truth in Lending Act • 12 C.F.R. 1026.42 CFPB Mortgage Origination Exam Procedures MMC Appraisal Review Procedures 31 C.F.R. Subtitle B Chapter X - Bank Secrecy Act

BSA/AML

Does the broker/lender have a BSA/AML policy that addresses: 1. System of controls for assuring compliance 2. Internal or third-party independent testing 3. Designation of individual(s) responsible for coordinating and monitoring compliance 4. Initial and periodic training of employees

Section 326 of the Patriot Act

MMC BSA/AML Program Exam Procedures

5. Customer identification program 6. Filing of suspicious activity reports 7. Record retention

Complaints

Does the broker/lender have a complaint policy that addresses: 1. Complaint intake and processing 2. Compliant management – tracking, resolution, and corrective action 3. Complaint escalation 4. Internal review – trend analysis 5. Reporting to the Board and/or senior management

CFPB RESPA Exam Procedures

CFPB Compliance Management Review Exam Procedures

6. Monitoring by management 7. Whistleblower complaints

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