Introduction to Mortgage Origination Examinations Training eBook

Internal Use Only

The Company’s policies and procedures are satisfactory. Compliance policies and procedures are adequate to manage risk of consumer harm in the products, services, and practices of the Company. Company policies and procedures are current, cover all products offered, and address Federal consumer financial laws. The Leadership Committee approves policies and procedures, and the Company documents the revision history. The policies and procedures are reviewed at least annually by senior management, the CCO, the Legal Department, and the Compliance Committee.

Internal Use Only

The Company’s policies and procedures are satisfactory. The Company developed and implemented a comprehensive set of risk-focused policies and procedures designed to promote compliance with ECOA and Regulation B. The Company implemented its current pricing and fair lending policies in April 2017 and October 2017, respectively. The Compliance Department’s Policy and Procedure Manager of fair lending reviews policies and procedures on an annual basis, or more frequently if required by operational or regulatory changes. While the procedures are satisfactory, transaction testing uncovered four instances in which employees did not follow the Company’s policies and procedures regarding document retention in practice. Specifically, the Company could not provide the documentation required by its Retail Pricing Policy FY 2018 to document pricing concessions for these four files. The policy approved in August 2019 raised the limit for price concessions to 300 basis points. Adherence to the documentation requirement of the policy is important to effectively manage fair lending risk associated with this increase in the concession limit.