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Updates - AML Audits, MERS Policy, TRID Checklist, Training Policy, Reverse Mortgage Disclosure, Fair Lending Pricing Concession Policy

8/3/2016

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  • AML Audits are due in August
  • MERS Policy Template
  • TRID Checklist Updates
  • Internal Training Programs 
  • Reverse Mortgage Disclosure
  • Fair Lending Pricing Concession Procedure

AML Self-Audit Checklist

For companies who adopted their AML policies in August 2012, when the FinCEN rule became effective, this serves as your reminder to initiate the review. You can use the Self-Audit Checklist we give you, as long as the sole-principal isn't the one who completes it. It doesn't have to be a vendor, but it must be completed by a third party, according to FinCEN rules.

The article is here. The checklist is here

MERS Policy Template
This type of policy is usually reserved for customers who are servicing mortgages, but we have seen a number of correspondents tagged for this request during renewal. If you do need it, please feel free to download it.

The article is here. The download is here.

TRID Checklist Updates
We know that you have had TRID up the wazoo, but this update to your processing/underwriting/QC checklist can help with catching LE and CD errors. Most of the errors result from COC items, so the checklist includes change dates. 

This is the processing/underwriting/QC Checklist
This is the closing document checklist

Internal Training Programs 

With many state audits, companies are failing to include documentation and benchmarks regarding internal training programs. As you may know, we include non-NMLS compliance training as part of the managed service, but we also provide the assessment and certification of existing training that has already been taken so that certain personnel (Loan Officers, especially) don't have to take training twice. 

Here is the training policy

Reverse Mortgage Disclosure
We recently had a client report that a state auditor was asking for information regarding how their reverse mortgage consumers knew who to complain to, among other things. We thought that was a pretty good case study in creating a disclosure. 

The article is here

Fair Lending Pricing Concession Procedure
With the increased scrutiny of loan originator compensation, pricing disparities in the customer's favor don't really trigger an alert for comp, but they could for fair lending. 

Here is a sample policy. 
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  • Home
    • Search our site
    • The CFPB and You
    • What Does a QC Plan Do?
    • Choosing the Right One
    • Free Sample Request Form
    • Request Discount Code
    • About Us >
      • About Us
      • FAQs
      • 100% Guarantee
      • Client List
    • Industry Blog
  • Single Policies
    • Single Policies
    • Free Sample Policies >
      • TIL-RESPA Integrated Disclosure (TRID)
      • HPML Appraisal Policy
      • Social Media
      • Ability to Repay
      • SAFE Act Policy
      • E-Sign Policy
      • Loan Originator Comp
      • Complaint Resolution
    • Disaster Recovery/Business Continuity Plan
    • Fair Lending/Fair Housing
    • Secondary Marketing-Loss Mitigation
    • Anti-Money Laundering (AML/BSA/SAR) Plan
    • Appraiser Independence - Appraisal Management
    • Anti-Predatory Lending (UDAAP)
    • Vendor Management
    • Business Plan
    • MERS QA Plan
  • Modules
    • Module System
    • Mortgage Compliance Manual
    • Quality Control Options >
      • Quality Control Options
      • Lender Quality Control Plan >
        • HUD-FHA Quality Control Plan
      • Broker QC Plan
    • Information Security - FACTA/Red Flags & ID Theft >
      • IT/Cyber Audit
    • Origination/Production Module
    • Processing Module
    • Underwriting/Credit Policy
    • Closing/Funding/Warehouse
    • Mortgage Ops & Employee
    • Wholesale/Third Party Origination
    • Mortgage Servicing Module >
      • Mortgage Servicing
      • Mortgage Sub-Servicing
      • MERS Quality Assurance (QA)
  • Packages
    • Packages
    • Anti-Money Laundering (AML/BSA/SAR) Package >
      • Annual AML/BSA Audit
      • Annual AML Training
      • Free AML/BSA SAR Evaluation
    • Cyber/IT Security Audit Package
    • State Audit Prep >
      • State Audit Prep Package
      • Pennsylvania Exam Preparation
      • Washington State Mortgage Lender Broker
      • New York Lender Broker Audit Prep
      • North Carolina Lender Broker
      • Ohio Mortgage Lender Broker
      • Texas Exam Preparation
      • State Examination Packages >
        • Supervisory Plan
    • Mortgage Banker Package
    • Correspondent Broker Pack
    • Lender Compliance Pack
    • Broker-Corr Compliance Pack >
      • Broker-Corr Compliance Pack
      • Specific Lenders Requirements
    • Processing Company Package
  • Services
    • Services
    • Annual Audit Preparation >
      • State Audit/Exam Prep >
        • State Examination System (SES) Support
    • Training Services >
      • AML Training
      • Fair Lending Training
      • ID Theft Training FACTA
      • Cybersecurity Training GLB Safeguarding
      • Fraud Red Flag and QC Training
      • Privacy Act - GLB Training
      • Advertising Compliance Training
      • New Employee Training
    • My Compliance VP - Manager >
      • My Compliance VP - Manager
      • Login Compliance Manager
      • Login Document Managment
      • Document Management Services
    • Updates and Downloads >
      • Updates and Downloads
      • Updates and Downloads (members)
    • Warehouse Lender/Agency Approval >
      • Comergence Upload Service
    • Request Review
    • How to: Customization Services >
      • Customization Services
      • How to: Downloading Documents
      • How to: Customize Your Manual
      • Free "Generic" Customization Offer