Introduction to Mortgage Origination Examinations Training eBook

Internal Use Only

Part 2 In other instances, examiners found that existing policies and procedures failed to provide the detail needed for the Company’s staff to use as a day-to-day reference. For example, while the Company had an existing Equal Credit Opportunity Act Policy, which appears to be a reiteration of the definitions and requirements set forth in Regulation B, along with additional procedures and checklists, it failed to provide staff with detailed procedures to ensure consumers were provided copies of all appraisals and other written valuations within the timeframes set forth in Regulation B.

Internal Use Only

Part 3 The Company’s Corporate Documentation Policy details its process for how its policies and procedures are drafted, approved, and published. The Compliance Policy further outlines the Chief Compliance Officer’s (CCO) responsibilities in developing and reviewing compliance policies and procedures. Examiners found policies and procedures are generally reviewed on an annual basis.