Introduction to Mortgage Origination Examinations Training eBook

Internal Use Only

The Company’s mortgage origination policies and procedures are satisfactory. Policies and procedures address compliance with applicable Federal consumer financial laws. They generally cover product or service lifecycles and are maintained and modified to remain current and serve as a reference for employees in their day-to-day activities. The Company’s policies support the efforts of its Compliance Program to prevent regulatory violations and associated risk of harm to consumers. The Company creates new or modifies existing policies and procedures as deemed necessary based upon internal audit results, self-assessments (monitoring), and/or regulatory changes.

Internal Use Only

Part 1 The Company’s policies and procedures related to reverse mortgage origination are deficient. Examiners identified policies and procedures that were not in place during the review period, lacked sufficient detail, or did not align with actual practices. Examiners also identified policies and procedures that did not adequately address compliance with applicable Federal consumer financial laws in a manner designed to prevent violations and to detect and prevent associated risks of harm to consumers. In several instances, policies were only put in place during the last half of 2019 or beginning of 2020. For example, the Compliance Policy was not developed until December 24, 2019. Similarly, examiners identified multiple policies and procedures related to compliance with loan officer compensation and licensing requirements, among others, that were also developed in the last quarter of 2019.