Introduction to Mortgage Origination Examiniations

Internal Use Only

5. Governance of Group Structure Holding company structure • Parent company board overall responsibility • Appropriate & clear governance framework • Board & senior management need understanding • Parent company aware of material risks & issues • Independent legal & governance responsibilities

Internal Use Only

5. Governance of Group Structure Parent Company should: • Establish governance framework

• Define subsidiary structure • Assess policies & procedures • Address conflicts of interests • Communications • Compliance • Effective internal audit