Audit Support and Approval Applications Services
Dealing with an audit can be frightening and time consuming. The key to a successful examination is preparation - do not give the auditor any reason to look further. Knowing the examiner's hot spots can help you prepare. Our Audit/Application Preparation Service collects all the required policies and procedures, stacks them in the order that the examiner requests, and provides a cover memo listing and explaining the scope, purpose and process in each request. This leaves nothing to question in the examination, meaning your examination or application can proceed quickly to resolution.
In addition, we can assist with preparing documentation to support lender approval applications, performing these same functions and uploading to Comergence or similar portals.
In addition, we can assist with preparing documentation to support lender approval applications, performing these same functions and uploading to Comergence or similar portals.
State Examiner
Individual state licensing agencies guidelines vary dramatically. With the decrease in the number of regulated companies, expect examiners to have more time to review each loan file. Pay special attention to:
Perhaps obviously, a lender or broker with a lot of complaints will face a stiff examination process.
- Fee Agreements/Lock-ins
- Fee/Cost Reconciliation - overcharges and unused third party fees
- Complaint resolution issues
- Marketing material and approval
- Fair Lending and Counteroffer Procedures
- Supervisory Plans for employees
Perhaps obviously, a lender or broker with a lot of complaints will face a stiff examination process.
Anticipating States With Written Policy and Procedure Requirements
- Arizona - Supervisory Policies and Procedures
- California (DFI) - Policies and Procedures, Information Security
- Georgia - Lender Quality Control Policies and Procedures
- Hawaii - Anti-Money Laundering Plan, Quality Control Plan,
- Illinois - Business Plan (Marketing Strategy), Complaint Resolution Plan, BSA/Anti-Money Laundering & SAR Reporting Process, TRID Policy & Procedure, TPO/Vendor Management Policy, Appraisal Policy & Procedure (AIR + Vendor Management), Credit Report Policy (FCRA, Vendor Management)
- Massachusetts - Policies and Procedures, WISP Written Information Security/Red Flag, Anti-Money Laundering, NMLS Call Reporting Process, Fair Lending Exception Pricing Policy, Reverse Mortgage Senior Discrimination, HMDA Policies and Procedures, Consumer Complaint, General Lending Compliance, ECOA and Fair Lending, Third Party Relationships (Vendor Management), Training, IT Risk Assessment, Disaster Recovery-Business Continuity, Compliance Management System
- Maryland - Origination/Quality Control (Higher Cost)
- Michigan - Approved or Denied Application Quality Control Plan, Information Security, Anti-Money Laundering Program, Financial Compliance Audit, Vendor Management, Compliance Policies and Procedures, Quality Control Production Process
- Nevada - Anti-Money Laundering Plan, Written Information Security Plan, Vendor Management Policies and Procedures, Quality Control Plan, Written Compliance Policies and Procedures, Identity Theft Plan, SAFE Act Policies and Procedures
- New Hampshire - FACTA Red Flag, GLB and Information Security, Anti Money Laundering, Advertising, Complaint Policy, Quality Control, Operations (Origination, Processing, Underwriting, Closing, Branch Management), Compensation, Licensing Policy, Employment, Disaster Recovery/Business Continuity, Ability to Repay, Records Retention, Privacy, Training Calendar, Compliance Policies and Procedures, Secondary Marketing, Referral Policy
- New Jersey - Plan of Operation (Origination, Processing, Underwriting, Closing, Post-Closing Quality Control, Physical Operations and Administration/Human Resources, Compliance, Predatory Lending Policy
- New York - Production and Underwriting Prcedures, Operations and Loan Level Accounting, Red Flags Rule, Safeguarding - document retention and destruction, Cybersecurity and Information Security, Fair Lending, Quality Control Audit, Privacy of Consumer Information, Third Party Vendor Management, Business Continuity, Employment and Training, MLO Compensation, Anti-Money Laundering
- North Carolina - Compliance, Anti-Predatory Lending, Business Plan
- Oregon - Responsible Person Supervisory Plan
- Pennsylvania - Advertising Policy, Employee Training Policies, Internal Audit Procedures, AML Program, Ability to Repay, Employment and Termination Procedures, Complaint Resolution, Red Flag ID Theft Prevention and Detection, GLB Privacy Act, Compliance Policies and Procedures, Employee Supervision - (Mortgage Act) and Origination/Underwriting (Repayment Ability),
- Texas - Quality Control Plan, Compliance Policies and Procedures, Red Flag and Information Security Plan, Anti-Monely Laundering (BSA) Plan, Advertising and Social Media Policies and Procedures, Employment and Screening Practices, Ability to Repay, TRID Compliance Policies and Procedures
- Utah - Principal Lending Manager/Reasonable Supervision
- Virginia - Written Business Plan, Branching Strategy, Compensation Plan, Processing Plan, Advertising Plan,
- Washington - Written Supervisory Plan, Red Flags Identity Theft Prevention Program, BSA/Anti-Money Laundering policy and procedures, Disaster Recovery/Business Continuity Plan, Complaint Resolution
HUD Audit97% of all HUD audits reference deficiencies in the lender's quality control plan. This is usually the result of not having a production quality control plan in place. Every lender is required to provide a post-closing plan at the time of approval, but at renewal or inspection, all of the production elements - origination, processing, underwriting, closing, human resources and operations - must be in place.
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FDIC AuditThe FDIC examiner will want to see specific written policies and procedures covering all areas of loan operations - from origination to post-closing. Having a complete set on hand can alleviate many concerns and save the organization substantial time and expense by mitigating the time spent in audit.
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FNMA/FHLMCThe GSE's have their own loan checklists which deal with loan documentation. Post closing issues focus on general fraud detection, but specifically occupancy re-verification. Policies and procedures are reviewed to insure consistency of process.
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Order Audit Preparation or Licensing Preparation Services
Includes:
- Identifying and Extracting Specific Policies and Procedures
- Enumerating to correlate with regulator request
- Cover Memo explaining and describing submission
$500 Per State