The events surrounding the CSBS and NMLS New Day Financial episode have led us to issue a policy intended for insertion into your compliance manual. (Story here) This is not a comprehensive training policy, but highlights all of the elements that should be contained within your own training program. Our policy highlights the fact that, within originator policies and procedures, there is a comprehensive SAFE Act Training policy. Within Compliance, there are various Federal Compliance Training Requirements. Within the Quality Control Plan, there is training on Fraud and Anti-Money-Laundering.
Download the policy here, and insert it in your compliance module under Employment, Hiring and Training.
This process applies to the origination, processing, closing and post-closing audit functions. It addresses time, and adjusts checklists for the personnel to ensure timing and content rules are met. Includes training material and updated checklists.
Click here to download Sample Policy