Introduction to Becoming an MMC EIC
RESTRICTED • Develop a scheduling process where the agency schedules examinations at least 12 months prior to the start dates of the examinations. Within the agency’s scheduling process, first consider whether the agency can join, accept, or leverage another scheduled examination on MMEs not identified as OMCs. • Use the Mortgage Examination Standards for all agency nonbank mortgage examinations. • Limit the scope of examinations based on company risk (i.e., consumer complaints, financial condition, etc.) and limit the review lookback period to two years. • Employ the Examination Moratorium from this Protocol to all non-OMCs supervised by the agency. • Train agency examiners to lead multi-state examinations. • Ensure that information sharing with other state regulators is seamless and unobstructed through SES and other methods of exchanging information as agreed upon through the 2011 CFPB and CSBS Information Sharing MOU. 18 • Encourage and allow other state agencies to join, accept, or leverage the agency’s examinations. • Utilize the MMC ROE template available in the SES Resource Library. • Review and follow the guidance for Networked Supervision activities in SES. 19 OCOE Support CSBS will provide administrative, technical, strategic, and logistic support to the MMC and OCOE Examination Teams, under the direction of the MMC. In addition: • The requirements of this Protocol will be monitored and measured by the MMC using SES and other sources of information. • Governance over this Protocol is provided by the NDSC. • Progress related to this Protocol may be reported to the CSBS Board of Directors. • The NDSC and MMC seek acceptance of and participation in the processes established by this Protocol from all state agencies with authority to supervise the mortgage industry, state mortgage regulator associations, and any state regulator committees responsible for mortgage supervision.
18 See 2011 CFPB and CSBS Information Sharing MOU 19 SES Portal: Networked Supervision
One Company, One Exam Mortgage / Protocol Page 12 of 12
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