Introduction to Mortgage Origination Examinations Training eBook

Internal Use Only

The Responsible Lending Manual states, “This policy and procedures manual is the core of the Company's compliance program and is required reading for all employees. Senior management and/or our Compliance Manager continually monitor changes to the mortgage regulatory environment and revise this manual accordingly.” However, there are multiple areas within this manual where information is out of date. Although there is annual training within each department, the compliance of the Underwriting Department cannot be considered adequate with outdated information in its policy and procedure manuals, especially considering the size and complexity of the Company’s operations. It is recommended that Management do a comprehensive review of the Company’s underwriting policies to address these areas.

Internal Use Only

Improvement in the area of social media consumer complaint response is necessary. As of the examination, consumer complaints are reviewed only if the complaint is submitted by phone or through the “Customer Voice” channel. In the ever-developing social media arena, many common types of consumer complaints could be overlooked or ignored if they are posted to a wall or sent via direct message to the social media account holder, including a corporate account, branch account, or a mortgage loan originator account. The Company’s complaint policy does not currently address these types of social media complaints or the process to handle a complaint of this nature.