Introduction to Becoming an MMC EIC

Guidance for Area for Review Report Writing Comments

Report Writing Tips

x The Report of Examination should clearly present conclusions that are well supported by facts obtained during the examination. x Be clear, concise, convincing, and accurate. The report should not include irrelevant background material but should include information that supports the findings. x Use simple, nontechnical language. Avoid jargon unless you know the Company will understand it or there are no simpler terms to describe something. Outline for Writing AFR Comments Section Conclusion x Brief Discussion of company policy/procedure and the company’s practice o Do they have a policy? o Is it sufficient and compliant? o Are the \ following it? x Are there any major issues in this area or one-offs? o If so, management’s attitude? o Remediated? ƒ Caught by examiners or the company? ƒ Fixed, in the process of being fixed, or ignored? x Any recommendations AFR Writing Samples x COMPANY policies and procedures do not outline the responsibilities of branch employees for reporting a complaint when the complaint is handled solely within the branch. x COMPANY is unable to ensure all complaints, regardless of where submitted, are appropriately recorded, and categorized. x Recommendation: Ensure consumer complaints, regardless of where submitted, are appropriately recorded, and categorized. Policies and Procedures ƒ COMPANY’s policies and procedures are deficient. ƒ 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. Complaints x COMPANY’S consumer complaint response is deficient.