Supervisors Symposium - December 2023

CONFIDENTIAL

MMC Supervisory Highlights – Federal Findings Top 10 Federal findings from 2022-2023

Regulation Exam Type

Finding Title

Origination Origination Origination Origination Origination Origination Origination Origination Origination Origination

TILA TILA TILA TILA TILA TILA TILA TILA TILA TILA

Charged Fees above Tolerance Limits

Good faith determination of estimates of closing costs

Unallowable Third-Party Fee

Failed to Issue a Corrected Closing Disclosure and Refund Within 60 Days of Consummation

Provided Inaccurate Loan Estimates

Collection of Excessive Fees

Mortgage loans - final disclosures – Subsequent changes Advertisement Missing Annual Percentage Rate

Mortgage loans - final disclosures – Provision of disclosures – Timing Closing costs details; other costs – Taxes and other government fees

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CONFIDENTIAL

MMC Ongoing Supervisory Matters

 Cybersecurity incidents (e.g., ransomware, data breaches) impacting mortgage companies. o Mr. Cooper/Nationstar, LoanCare, ongoing MMC targeted exam & enforcement matter.  Hometown Lenders, Inc. failure to satisfy financial obligations to employees, federal mortgage insurers and guarantors, warehouse lenders, and investors. State orders (revocations and C&Ds) ongoing and MMC information requests to targeted companies pending.  LO Comp Rule violations – changing the mortgage lead source; manipulating loan terms to increase branch / MLO compensation.  Ability of agencies to examine for and cite failure to properly monitor third-party servicers and other settlement service providers and ensure compliance with federal regulations on multistate exams.

 Mortgage servicer financial condition monitoring and distressed company monitoring and outreach

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