Introduction to Mortgage Origination Examinations Training
4. Appraiser engagement – use of appraisal management companies 5. Transfer of appraisals 6. Referrals of appraisal misconduct 7. Appraisal review/quality control 8. Training of staff on appraiser independence requirements
12 C.F.R. 1026 – Truth in Lending Act 12 C.F.R. 1026.42 CFPB Mortgage Origination Exam Procedures MMC Appraisal Review Procedures 31 C.F.R. Subtitle B Chapter X - Bank Secrecy Act
BSA/AML
Does the broker/lender have a BSA/AML policy that addresses: 1. System of controls for assuring compliance 2. Internal or third-party independent testing 3. Designation of individual(s) responsible for coordinating and monitoring compliance 4. Initial and periodic training of employees
Section 326 of the Patriot Act
MMC BSA/AML Program Exam Procedures
5. Customer identification program 6. Filing of suspicious activity reports 7. Record retention
Complaints
Does the broker/lender have a complaint policy that addresses: 1. Complaint intake and processing 2. Compliant management – tracking, resolution, and corrective action 3. Complaint escalation 4. Internal review – trend analysis 5. Qualified written requests, Notices of Error and Requests for Information 6. Reporting to the Board and/or senior management
12 C.F.R. § 1024 – Real Estate Settlement Procedures Act
12 C.F.R. § 1024.35 12 C.F.R. § 1024.36
CFPB RESPA Exam Procedures
7. Monitoring by management 8. Whistleblower complaints
CFPB Compliance Management Review Exam Procedures
Made with FlippingBook - Online Brochure Maker