Policy, Procedures, and Examinations - Mortgage Brokers


In this article, the first of a two-part series, I am going to provide a chart of certain core policies and procedures that a mortgage broker should obtain and continually update, as regulations change. I will also provide some useful policy implementation guidance relating to preparing for a state banking examination.

In part two of this series, I will address the central policies and procedures that are needed by mortgage bankers.

Perhaps the most difficult task of the independent mortgage professional is to obtain and maintain a full set of policies and procedures. Too often, a broker’s approach to compiling adequate policy statements is reactive; that is, the demand comes about in order to meet a regulator’s expectations or in anticipation of a forthcoming examination.

Many brokers simply make it their business to always be prepared, especially in this highly regulated financial services industry. I have said many times, preparation is protection! Indeed, I have written extensively on this theme.

Nevertheless, all the policy statements in the world will not impress a regulator if that policy’s stated requirements are not really implemented. In other words, the examiner will determine if a firm’s procedures are actually being followed.

Let’s put it this way: a policy statement, without implementation, is merely pontification!

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Jonathan Foxx, Lenders Compliance Group | Attorney Advertising

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