Introduction to Mortgage Origination Examinations Training eBook

Internal Use Only

The Company failed to ensure all employees completed annual on-going AML training under the program and new hire training within 30 days. Management must ensure policies are followed, that new employees receive AML training within 30 days of hire, and that on-going AML training is completed in the same year it is assigned. The Compliance Officer is responsible for oversight of the training program and should verify that employees are provided training in a timely manner and training is completed according to the schedules set forth in the program.

Internal Use Only

A defined written policy and procedure addressing Regulation B’s definition of an application, specifically the Company’s ECOA policy and procedures, did not clearly reflect pertinent aspects of Regulation B including defining when an application is established, and subsequent borrower notice requirements based upon that Regulation B application date. Although the Company has adequate applicable Regulation B application training, policies, and procedures regarding adverse notices, and notice of an incomplete application, the policies and procedures did not address borrowers requesting credit which can establish an application and trigger the beginning of notice timing requirements. The Company also represented that it did not have a triggering or tracking mechanism within its loan origination system to recognize a Regulation B application and determine the timing of subsequent required notice(s) to borrowers. Senior management acknowledged these deficiencies and represented that they would begin making corrections and enhancements while examiners were still onsite.