Introduction to Becoming an MMC EIC
Compliance Program
regulatory compliance. The Compliance Department consistently monitors changes to investor and regulatory requirements to update origination policies and procedures and issues those to applicable employees via email. Provident has established adequate written policies to manage consumer issues and complaints. Consumer issues and complaints are acknowledged, tracked, and resolved in a timely manner by the Consumer Compliance Department. Provident has an Audit Department that consists of both internal and external audit. These function to provide scheduled reviews of operating processes and controls. In addition, Provident conducts pre-funding and post-funding quality control reviews. Provident’s audit and monitoring functions adequately cover a wide scope on a yearly basis that helps it limit violations of law and consumer harm. Provident maintains an adequate and comprehensive Bank Secrecy Act and Anti-Money Laundering Program. Provident’s Internal Audit Manager at a minimum, annually tests the policy, and at least annually trains appropriate staff via an internal training system, Provident Funding University. Compliance Program - Matters Requiring Attention The Examination Team identified the following Matter Requiring Attention related to the The Retail Policy and Procedures, section 7.6.2.1 (P. 57), states "Provident Funding charges a $1,350 administration fee on all first mortgages." Collection of this fee type may violate North Carolina General Statutes (NCGS) §§ 24-1.1A(c)(1)f and 53 244.111(5), which prohibit a lender from collecting miscellaneous fees that exceed, in aggregate, 1/4 of 1 percent of the loan amount or $150, whichever is greater. Provident must review and update their written policy to align with its current practice and state regulation. institution’s Compliance Program. Matter Requiring Attention 01 :
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