Introduction to Mortgage Origination Examinations Training eBook

Information Sharing and Privacy

12 C.F.R. 1016 – Privacy of Consumer Financial Information 15 U.S.C. 6801 et seq – Title V of the Gramm-Leach-Bliley Act CFPB Privacy of Customer Financial Information – Gramm-Leach-Bliley Act Exam Procedures

Does the broker/lender have an information sharing and privacy policy that addresses:

1. Notification to borrowers of privacy policy 2. Timing and content of initial privacy notice 3. Timing and content of annual privacy notice 4. Handling of nonpublic personal information 5. Consumers right to opt out 6. Duties of financial institutions 7. Information sharing with affiliates. 8. Information sharing with nonaffiliated third parties. 9. Safeguards Rule compliance (GLBA)

Internal Audit

CFPB Compliance Management Review Exam Procedures

Does the broker/lender have an internal audit policy that addresses: 1. Internal audit functions and charter 2. Governance processes 3. Organizational independence from business line and compliance management functions 4. Risk assessments

5. Audit plan approval 6. Ongoing monitoring 7. Sampling techniques

8. Documentation Standards (workpapers) 9. Reports to Board and/or Management 10. Scope identification

MLO Compensation 12 C.F.R. 1026 – Truth in Lending Act  12 C.F.R. 1026.36

Does the broker/lender have a MLO compensation policy that addresses: 1. Permitted compensation 2. Prohibited compensation