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States are Requiring Quality
Control Process for New Broker/Lender Licenses
As the dust from the credit
crisis continues to fly, many states are placing higher barriers to
entry for lender or broker approval. The primary issue is control
of employees - brokers and lenders must have written policies in place
to show that employees understand ethical, correct practices in place.
Our Broker, Lender or Wholesaler packages
provide this.
Arizona -
Policies and Procedures
California (DFI) -
Policies and Procedures
Georgia -
Lender Quality Control Policies and Procedures
Illinois -
Quality Control Plan
Massachusetts -
Policies and Procedures
Michigan -
Quality Control Plan
Nevada -
Complete Operation Policies and Procedures
New York -
Policies and Procedures
Oregon -
Responsible Person
Texas -
Best Practices/Compliance Policies and Procedures
Utah -
Principal Lending Manager/Reasonable Supervision
Washington -
Written Supervisory Plan
State Audit/Examination
Focus
Obviously, a lender or broker with a lot of complaints will face a stiff
examination process. Examination preparation is only part of the
problem. Auditors are now looking at marketing practices, and
whether the lender or broker encourages Hybrid or Sub-Prime
Applications.
You must have procedures in
place to document marketing, counteroffer and complaint resolution
issues, among hundreds of others. Our
Origination Module details
compliance with State Audit Guidelines.
Audit Requirements for
Sub-Prime/Hybrid Loan Guidance -
40 State Regulators Adopt Drastically Stringent Procedures and
Audit Requirements
Agencies/Investors Requiring
Quality Control Process
FHA
FNMA
FHLMC
VA
FDIC
OCC
NCUA
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Most investors are
referring to the Fraud/Audit
and Compliance Module when they are asking for a quality
control plan - a non-rigorous review of a document that shows
the broker or lender knows what a post-closing quality control
review is.
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Some States and most
warehouse lenders want a complete description of an applicant's
or company's operating procedures to inspect efficiency or to
guard against illicit practices. This is the
broker, banker or wholesaler package.
This can be a
useful learning process for both regulator or warehouse bank and
the broker or lender - it is extensive documentation of business
practices. |