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