Introduction to Becoming an MMC EIC
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EIC and SPOC Pool and Resources The MMC will develop a process for identifying potential EIC candidates from each state agency. The purpose is to create a pool of experienced regulators committed to serving as EICs or as SPOCs on future OCOEs. The MMC will coordinate with the CSBS Education Foundation to identify EIC candidates and provide tools, certifications, training, and mentoring opportunities, including the ability to shadow other EICs/SPOCs on OCOEs. Scope of Examinations The scope of each OCOE is limited to mortgage origination or mortgage servicing for the review. The MMC may also consider limiting the scope of an OCOE to only focus on certain AFRs, such as Financial Condition or Information Technology and Cyber Security. As part of the examination scheduling process the MMC determines the primary scope of each OCOE (i.e., origination or servicing). The Mortgage Examination Standards are applied in full or in part to each OCOE based on the exam program and scope selected. Each OCOE is limited to a review lookback period of two years. The MMC may provide the EIC, in consultation with the SPOC and MMC Liaison, with the flexibility and authority to adjust the scope of the OCOE under certain conditions. Any addition or removal of an Area for Review (AFR) included in the Mortgage Examination Standards for the OCOE should be based on risk, significance, and relevance of the AFR to the operations of the OMC. Any request for an increase to the lookback period of two years must be approved by the MMC. Examination Participation Parameters To ensure the successful implementation of OCOE supervision, participating state agencies must agree to comply with all parameters outlined in this Protocol and not deviate from the activities of the multi-state exam team. In addition to agreeing to the principles set forth above in Scope of Examinations , each participating agency must: • Utilize SES fully and consistently for OCOEs. • Designate an agency lead examiner responsible for communicating with the EIC and/or company, completing or assigning AFR assignments, and providing ROE write-ups. • Limit the exam review to the Mortgage Examination Standards applied to the OCOE. The exam standards applied to each OCOE depend on the exam program type and scope selected. Agencies can add any non duplicative, state-specific information requests upon approval from the EIC. The EIC has the flexibility and authority to adjust the scope of the examination in consultation with the SPOC and MMC Liaison. Nothing in this Protocol shall prevent or limit a state agency from receiving the company documentation needed to complete a review within the examination scope. • When appropriate, agree to use the mortgage regulatory compliance technology to automate loan file reviews to increase productivity and free examiner resources. • Adopt uniform, networked behaviors within the agency and among the examiners assigned to the OCOE. • Adhere to the 12-month Examination Moratorium.
One Company, One Exam Mortgage / Protocol Page 9 of 12
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