Introduction to Becoming an MMC EIC

ƒ Policies and procedures contained gaps, which resulted in an inadequate design of the loan origination system, documentation practices specific to changes in circumstance, and understanding of the mortgage origination disclosure requirements. ƒ Examiners found that the Compliance Department did not require review or approval of business line policies, which led to incomplete coverage of the Company’s compliance responsibilities. ƒ Recommendation: Implement a centralized system for the creation, tracking, and maintenance of policies and procedures to ensure they are current and accessible for employees in their day-to-day activities.

Training x COMPANY’s training is satisfactory.

x Compliance professionals have access to training that is necessary to administer a compliance program tailored to COMPANY’s risk profile, business strategy, and operations. x Compliance training is comprehensive, timely, and specifically tailored to the responsibilities of the staff receiving it.

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