In this article, I outline the key questions that should be asked, the answers to which will determine the extent, depth, and integrity of a culture of compliance. I am going to take you through a set of questions that will form the basis of a self-assessment. This type of internal review should be undertaken in order to set a baseline and determine progress towards compliance with mortgage acts and practices, and certainly the new mortgage rules. During any such evaluation, keep in mind that this is a due diligence process which is subject to an institution’s size, products offered, risk mitigation, complexity, and overall strength of the existing compliance management system.
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Topics: Chief Compliance Officers, Compliance, Corporate Culture, Dodd-Frank, Due Diligence, ECOA, HOEPA, Internal Controls, Mortgage Escrow Account, Mortgage Loan Originators, Mortgage Servicers, Mortgage Servicing Rules, Mortgages, RESPA, TILA, Valuation, Year-End Compliance Checklist
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.
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