Written Supervisory Plan
You must parse the requirement before submitting a generic "supervisory plan." In the same way that a business plan is different from state to state, a "supervisory plan" requires specific answers about who the manager is and who that person supervises. Rather than a generic document, you must draft out the answer to these questions.
At issue: many states that require supervisory plans have figured out that companies will try to avoid accountability for employee actions by saying "the employee did it, not us." The regulator wants to eliminate this excuse, so requires you to tell the employee specifically what their job entails.
When there is a written requirement for a Written Supervisory Plan, the state may have detailed format for providing the information required. These states include WA, OR, ID, NV. While the questionnaire may provide basic responses, to actually supervise employees you must have operating policies and procedures.
So, you must have an overall employee operating plan, such as an HR module. In addition, you must have the basic policies and procedures for regulatory compliance for all employees. Then, if you have licensed originators, you must have origination policies and procedures. If you process loans in state and you have processors, you must have processing policies and procedures. The same is true for closing, underwriting and any other function, such as wholesale, that you have.
Effectively, the mortgage correspondent package or mortgage banker package meets this requirement. Simply print the documents as the applicable title to a PDF. E.g.; 2-0 Compliance would be "2-0 All Employee Compliance Related Supervisory Plan." "3-0 Originator Supervisory Plan" etc.
If you are a very small company where only the principals are active in originating, you can use the Quality Control Plan and Compliance Policies and procedures and call them "Employee Supervisory Plan."
- Who is the manager - Name and Location
- Who does he or she supervise - Title, Position, Location, number of people
- How will the manager supervise - actual strategy
- What is the scope of the work the employee performs - can be a job description
At issue: many states that require supervisory plans have figured out that companies will try to avoid accountability for employee actions by saying "the employee did it, not us." The regulator wants to eliminate this excuse, so requires you to tell the employee specifically what their job entails.
When there is a written requirement for a Written Supervisory Plan, the state may have detailed format for providing the information required. These states include WA, OR, ID, NV. While the questionnaire may provide basic responses, to actually supervise employees you must have operating policies and procedures.
So, you must have an overall employee operating plan, such as an HR module. In addition, you must have the basic policies and procedures for regulatory compliance for all employees. Then, if you have licensed originators, you must have origination policies and procedures. If you process loans in state and you have processors, you must have processing policies and procedures. The same is true for closing, underwriting and any other function, such as wholesale, that you have.
Effectively, the mortgage correspondent package or mortgage banker package meets this requirement. Simply print the documents as the applicable title to a PDF. E.g.; 2-0 Compliance would be "2-0 All Employee Compliance Related Supervisory Plan." "3-0 Originator Supervisory Plan" etc.
If you are a very small company where only the principals are active in originating, you can use the Quality Control Plan and Compliance Policies and procedures and call them "Employee Supervisory Plan."
Small BrokerIf you are a closely held mortgage broker where the only employees are principals, you can use the Broker Compliance Package as your Supervisory Plan.
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Broker CorrespondentIf you have originator employees, outside originators and/or processors, as well as office staff, you may use the Complete Broker Correspondent package as a supervisory plan.
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Banker LenderIf you have originator employees, outside originators and/or processors, underwriters and closers, as well as office staff, you may use the Complete Lender/Banker package as a supervisory plan
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