Introduction to Becoming an MMC EIC

First page Table of contents 1 Next page Last page

January 9-11, 2024 Live Virtual

@ www.csbs.org ♦ @csbsnews

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

Introduction to Becoming an MMC EIC Live Virtual January 9 ‐ 11, 2024

Tuesday, January 9, 2024 1:00 pm – 2:00 pm

Introduction & Pre ‐ Course Review

MMC EIC ‐ What You Need to Know

2:00 pm – 2:30 pm

Break/Icebreaker

2:30 pm – 2:45 pm

MMC EIC ‐ What You Need to Know

2:45 pm – 4:00 pm

Wednesday, January 10, 2024 1:00 pm – 1:15 pm

Prior Day Review

MMC EIC ‐ What You Need to Know

1:15 pm – 2:15 pm

Break/Icebreaker

2:15 pm – 2:30 pm

Writing the Report of Examination (ROE)

2:30 pm – 4:00 pm

Thursday, January 11, 2024 1:00 pm – 1:15 pm

Prior Day Review

How to Run an Effective Meeting

1:15 pm – 2:15 pm

Break/Icebreaker

2:15 pm – 2:30 pm

Effective Meeting Activities

2:30 pm – 3:30 pm

Wrap Up & Conclusion

3:30 pm – 4:00 pm

Internal Use Only

Introduction to Becoming an MMC EIC Day 1

Internal Use Only

Introductions

• Name • State agency • Fun fact

Internal Use Only

Supervising Examiner / Investigator Idaho Department of Finance daniel.kline@finance.idaho.gov Daniel Kline

Internal Use Only

Financial Non-Depository Examiner Maryland Office of the Commissioner of Financial Regulation matthew.mainolfi@maryland.gov Matt Mainolfi

Internal Use Only

Field Examiner Supervisor Washington State Department of Financial Institutions lindsay.stenger@dfi.wa.gov Lindsay Stenger

Internal Use Only

Financial Examiner Field Supervisor Washington State Department of Financial Institutions jacob.monson@dfi.wa.gov Jacob Monson

Internal Use Only

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

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

Internal Use Only

Pre-Course Review

Internal Use Only

Key Points – Pre-Course

Internal Use Only

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)

Internal Use Only

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

Internal Use Only

Multistate Mortgage Committee (MMC)

Anya Tabb (WA) 2022 Chair

Brenda Fanning (WY) Chair

Allie Wessel (WI) Vice Chair

Craig Christensen (IA)

Kristin Rice (NC) 2023 Chair

Christine Brooks (MD)

Kevin Cuff (MA)

Mark Hastie (MN)

Paul Rhoades (FL)

Sheila Oliver (CA)

Internal Use Only

Multistate Mortgage Committee (MMC) What does the MMC do? • Since January 2019, conducted 35 multistate exams, including the OCOE Pilot that closed July 2022 •Works closely with Risk Profiling Group (RPG) to determine the multistate mortgage entities (MMEs) to examine each year •Works closely with Consumer Financial Protection Bureau (CFPB) to conduct 2 ‐ 3 coordinated exams annually • Typically conducts 7 ‐ 10 mortgage origination & servicing multistate exams annually

Internal Use Only

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 limit participation to 10 state agencies per exam • Limiting participants encourages agencies to accept or leverage results & reduces regulatory burden of the MME being examined

Internal Use Only

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

Internal Use Only

Multistate Mortgage Committee (MMC) MMC Efforts: • Continuously works to improve multistate supervisory & exam process • Recent projects include revising MMC Mortgage Examination Manual, streamlining MMC Report of Examination, drafting OCOE Protocol & 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

Internal Use Only

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

Internal Use Only

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

Internal Use Only

Multistate Mortgage Committee (MMC)

Internal Use Only

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

Internal Use Only

Overview of SES

Internal Use Only

Overview of SES

SES Benefits

Library

Company Enrollment/Communications

SES Milestones

Internal Use Only

Benefits of SES

Internal Use Only

Benefits of SES - Regulators

Standardize Collaborate

Data

Safeguard

Internal Use Only

Benefits of SES - Regulators

Standardize • Supervisory process

Collaborate

Data •Risk ‐ based •Readily available

Safeguard

•Foster

• Sensitive

amongst state agencies

information

Internal Use Only

Benefits of SES - Companies Consistency Reduced Burden

Assurance

Internal Use Only

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

Internal Use Only

Overview of SES

SES Benefits

Library

Company Enrollment/Communications

SES Milestones

Internal Use Only

SES Library

Areas for Review

Information Requests

SES

References Procedures

Internal Use Only

SES Library

Areas for Review

Information Requests

SES

References Procedures

Internal Use Only

SES Library

Information Requests

Areas for Review

SES

References Procedures

Internal Use Only

SES Library

Areas for Review

Information Requests

SES

Procedures

References

Internal Use Only

SES Library

Areas for Review

Information Requests

References Procedures SES

Internal Use Only

SES Library Management

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

Internal Use Only

SES Library Management

Agency Specific

Standard

1 2

Internal Use Only

SES Library Management

Non Core

Core

1 2

Internal Use Only

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

Internal Use Only

SES Exam Scope

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

Mortgage: • Lender • Broker • Servicer • Master Servicer

Internal Use Only

Overview of SES

SES Benefits

Library

Company Enrollment/Communications

SES Milestones

Internal Use Only

Company Enrollment

Agency Sends SES Enrollment Request to Company

Company Receives Email to Activate Okta Account

Company Logs into SES

Internal Use Only

Company Communications

Question: What are some of the benefits of SES?

Internal Use Only

Overview of SES

SES Benefits

Library

Company Enrollment/Communications

SES Milestones

Internal Use Only

Overview of SES

SES Milestones

Internal Use Only

SES Milestones

Pending

Scheduled

Planning

In ‐ Flight

Drafting

Close ‐ Out

Closed

Internal Use Only

SES Milestones

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

Pending

Internal Use Only

SES Milestones

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

Scheduled

Internal Use Only

SES Milestones

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

Planning

Internal Use Only

SES Milestones

• Review Findings • Schedule Exit Meeting • Upload Report

In ‐ Flight

Internal Use Only

SES Milestones

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

Drafting

Internal Use Only

SES Milestones

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

Close ‐ Out

Internal Use Only

SES Milestones

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

Closed

Internal Use Only

SES Demo

Internal Use Only

Questions

Internal Use Only

How to Coordinate an MMC Examination

Internal Use Only

What you need to know: • Participants

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

• Resources • Technology

Internal Use Only

Participants

Teamwork makes the dream work.

Internal Use Only

Participants

MMC EIC

COMPANY

SPOC

STATES

MMC

CSBS

Internal Use Only

Participants

• Project Manager • Facilitator • Should not lead a

complex subcommittee

MMC EIC (you!)

Internal Use Only

Participants

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

MMC EIC (you!)

Internal Use Only

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!)

Internal Use Only

Participants

Individual EIC Knowledge and Experience Utilize it!

MMC EIC (you!)

Internal Use Only

Participants

MMC EIC

SPOC

COMPANY

MMC Liaison

STATES

CSBS

Internal Use Only

Participants

Single Point of Contact (SPOC) for MMC EIC

SPOC

Internal Use Only

Participants

• Mentor/Advisor • Liaison • Resource

• Participates in meetings • Reviews draft documents

SPOC

Internal Use Only

Participants

MMC EIC

COMPANY

SPOC

MMC Liaison

STATES

CSBS

Internal Use Only

Participants

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

MMC Liaison

Internal Use Only

Participants

MMC EIC

COMPANY

SPOC

MMC Liaison

STATES

CSBS

Internal Use Only

Participants

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

CSBS

Internal Use Only

Participants

MMC EIC

COMPANY

SPOC

MMC Liaison

STATES

CSBS

Internal Use Only

Participants

State EIC • Primary contact • ROE:

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

STATES

Internal Use Only

Participants

State Examiners • File reviewers • Subcommittee leads • Write section

STATES

Internal Use Only

Participants

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

STATES

Internal Use Only

Participants

MMC EIC

COMPANY

SPOC

MMC Liaison

STATES

CSBS

Internal Use Only

Participants

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

COMPANY

Internal Use Only

Participants

Company Management: • Meetings during exam • Coordinated through

Company Primary Contact

COMPANY

Internal Use Only

Communication

Conference Calls, Emails, Notes, Oh My!

Internal Use Only

Communication

States

Company

MMC

Conference Call Tips

Meeting Notes Tips

CFPB

Internal Use Only

Communication - States

Meetings

Conference Calls

Emails

SES

EIC

Internal Use Only

Communication - States

State Examination System (SES) • Interactions here

Internal Use Only

Communication - States

Email • Reminders • File structure path

Internal Use Only

Communication - States

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

Internal Use Only

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

Internal Use Only

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

Internal Use Only

Communication - States

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

Weekly (pre ‐ exam)

Internal Use Only

Communication - States

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

Mid ‐ Week Check ‐ Ins (on ‐ site)

Internal Use Only

Communication - States

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

Week After On ‐ Site

Internal Use Only

Communication - States

Week Report Submissions Due: • Any issues

• Template reminder • Write-up deadline

Week Report Submissions Due

Internal Use Only

Communication - States

Finalize Ratings: • Thank examiners • Finalize ratings

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

Finalize Ratings

Internal Use Only

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

Question: What other topics may be important for this introductory meeting?

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

Internal Use Only

Communication - Company

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

After Loans Received & IRs Start

Internal Use Only

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

100

Internal Use Only

Communication - Company

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

Other Possible Calls

101

Internal Use Only

Communication - Company

Exit Meeting: • Final exit with Company • Time zones

Exit

102

Internal Use Only

Communication – MMC, SPOC & CSBS

Phone Calls

Emails

SES

EIC

103

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

104

Internal Use Only

Communication

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

105

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

106

Introduction to Becoming an MMC EIC Day 2

107

Internal Use Only

Examination Process

“The secret to getting ahead is getting started.”

108

Internal Use Only

Examination Process

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

109

Internal Use Only

Examination Process

Beginning • Requests On-Site Week

Report Writing

Ratings

MMC Review of Draft ROE

Final Exit & Final Report

Response Review

Closing the Exam

110

Internal Use Only

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

111

Internal Use Only

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

112

Internal Use Only

Examination Process

On-Site Week: • Introductory meeting/tour

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

113

Internal Use Only

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

114

Internal Use Only

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

115

Internal Use Only

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

116

Internal Use Only

Examination Process

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

117

Internal Use Only

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

118

Internal Use Only

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

119

Internal Use Only

Examination Process

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

120

Internal Use Only

Timing/Schedule

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

121

Internal Use Only

Timing/Schedule

Outline of Exam

Planning On-Site Week

Scheduling Meetings

EIC’s Time

122

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.)

123

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

124

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

125

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

126

Internal Use Only

Timing/Schedule MMC Exam Timeline – Prior to Exam Start

Request ISB/EP Form

EIC & SPOC Call Company

120

Exam Notification Letter

Exam Plan & IR Due Date

127

Internal Use Only

Timing/Schedule MMC Exam Timeline – Prior to Exam Start

Loan Files Due From Company

EIC Finalizes Onsite Week

EIC Reviews Exam Plan

EIC & SPOC Call States & Company

128

Internal Use Only

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

EIC Finalizes and Uploads Initial Draft ROE

MMC ROE Preparation

States Submit Findings & Assignments

129

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

EIC Schedules a Final Exit Meeting With the Company

130

Internal Use Only

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

Company Response Due

EIC Closes the Exam in SES

130

120

Accept/Reject Exam Response From Agencies

131

Internal Use Only

Resources

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

132

Internal Use Only

Resources

Manual

Templates

Subcommittee Guidance

Contacts

133

Internal Use Only

Resources

Manual

Rating Information

Regulation Information

134

Internal Use Only

Resources

Templates

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

135

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!

136

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

137

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.”

138

Internal Use Only

Technology

Helpful Contacts & Resources

Encrypted Email

Technology Overview

File Organization

139

Internal Use Only

Technology

Technology Overview

External Software

SES

Box

140

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

141

Internal Use Only

Technology

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

Helpful Contacts & Resources

142

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

143

Internal Use Only

Questions

144

Internal Use Only

145

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

146

Internal Use Only

147

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

Internal Use Only

Session Learning Objectives: 2. Discuss best practices for report writing

Internal Use Only

Session Learning Objectives: 3. Apply concepts to writing exercises.

Internal Use Only

Writing the Report of Examination (ROE)

Internal Use Only

What do you think is most important when writing the 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

Internal Use Only

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

Internal Use Only

Content

Internal Use Only

Content

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

Internal Use Only

Content

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

Internal Use Only

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?

Internal Use Only

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?

Internal Use Only

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?

Internal Use Only

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?

Internal Use Only

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.

Internal Use Only

Resources • The Business Writer’s Handbook: http://www.grammarbook.com

Internal Use Only

Exercise

Internal Use Only

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

Internal Use Only

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

Internal Use Only

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

Internal Use Only

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

Internal Use Only

How to Run an Effective Meeting

Internal Use Only

Agenda

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

• Planning • Preparing

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

Internal Use Only

Purpose of the Meeting

Internal Use Only

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.

Internal Use Only

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

Internal Use Only

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

Internal Use Only

Is the Meeting Necessary?

Internal Use Only

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

• Memo • Letter • Portal

Internal Use Only

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

Internal Use Only

Question: Tell me about a time when you have been at a meeting when it wasn’t necessary.

Internal Use Only

Meeting Logistics

Internal Use Only

Meeting Logistics

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

Internal Use Only

Meeting Optics

Internal Use Only

Meeting Optics

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

• Facial expressions • Posture & gestures

Internal Use Only

Question: How does starting the meeting late or attendees showing up late impact the meeting?

Internal Use Only

Question: Examples of how nonverbal communication can show disinterested in the meeting.

Internal Use Only

Planning for the Meeting

Internal Use Only

Planning for the Meeting

• Agenda • Participants • Timing • Location

Internal Use Only

Question: Tell me about a time where you’ve attended a well-planned meeting and why it went well.

Internal Use Only

Preparing for the Meeting

Internal Use Only

Preparing for the Meeting

• Provide attendees agenda • Assign scribe • Distribute documents

Internal Use Only

Preparing for the Meeting

• Prepare yourself • Questions • Information requests • Anticipate

Internal Use Only

During the Meeting

Internal Use Only

During the Meeting

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

Internal Use Only

During the Meeting Be Engaged • Listen

• Be confident • Participation • Follow agenda

Internal Use Only

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

Internal Use Only

Question: How does participation (or the lack of it) impact a meeting?

Internal Use Only

Question: Discuss a time where you have had a meeting that got out of control and the impacts it had on the meeting.

Internal Use Only

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

Internal Use Only

Ending the Meeting

Internal Use Only

Ending the Meeting

• Questions • Action items

• Set expectations • Thank attendees

Internal Use Only

After the Meeting

Internal Use Only

After the Meeting

• Distribute documents • Distribute important notes • Action items

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

Internal Use Only

Activities

RESTRICTED

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.

RESTRICTED

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

One Company, One Exam Mortgage / Protocol Page 2 of 12

RESTRICTED

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

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).

One Company, One Exam Mortgage / Protocol Page 3 of 12

RESTRICTED

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.

One Company, One Exam Mortgage / Protocol Page 4 of 12

Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32 Page 33 Page 34 Page 35 Page 36 Page 37 Page 38 Page 39 Page 40 Page 41 Page 42 Page 43 Page 44 Page 45 Page 46 Page 47 Page 48 Page 49 Page 50 Page 51 Page 52 Page 53 Page 54 Page 55 Page 56 Page 57 Page 58 Page 59 Page 60 Page 61 Page 62 Page 63 Page 64 Page 65 Page 66 Page 67 Page 68 Page 69 Page 70 Page 71 Page 72 Page 73 Page 74 Page 75 Page 76 Page 77 Page 78 Page 79 Page 80 Page 81 Page 82 Page 83 Page 84 Page 85 Page 86 Page 87 Page 88 Page 89 Page 90 Page 91 Page 92 Page 93 Page 94 Page 95 Page 96 Page 97 Page 98 Page 99 Page 100 Page 101 Page 102 Page 103 Page 104 Page 105 Page 106 Page 107 Page 108 Page 109 Page 110 Page 111 Page 112 Page 113 Page 114 Page 115 Page 116 Page 117 Page 118 Page 119 Page 120 Page 121 Page 122 Page 123 Page 124 Page 125 Page 126-127 Page 128 Page 129 Page 130 Page 131 Page 132 Page 133 Page 134 Page 135 Page 136 Page 137 Page 138 Page 139 Page 140 Page 141 Page 142 Page 143 Page 144 Page 145 Page 146 Page 147 Page 148 Page 149 Page 150 Page 151 Page 152 Page 153 Page 154 Page 155 Page 156 Page 157 Page 158

Made with FlippingBook - Online catalogs