In their article, “Preparing for CFPB Servicing Exams, Avoiding Common Mistakes With Servicing Transfers and Private Mortgage Insurance,” published in the February 2017 issue of Mortgage Compliance Magazine, Chris Ortigara and Jim Shankle highlight key areas for mortgage servicers to focus on when preparing for CFPB exams. The article identifies common mistakes related to servicing transfers, loss mitigation, and private mortgage insurance (PMI) compliance. Servicers are encouraged to implement best practices, improve document retention, and ensure that both regulatory and investor requirements are met to avoid penalties during CFPB examinations.
The Second Line of Defense: Are the Stars Aligned?
In her article, “The Second Line of Defense: Are the Stars Aligned?” published in ABA Bank Compliance (now ABA Risk and Compliance) in October 2016, Liza Warner emphasizes the importance of aligning the first and second lines of defense in managing compliance risk. The first line, responsible for daily operations, relies on the second line for oversight, guidance, and monitoring. Effective collaboration between these lines creates a strong compliance program where risks are well-managed. Warner stresses that this alignment is essential for embedding compliance into an institution’s culture, ensuring regulatory adherence and organizational protection.
Are you Integrating TRID into your Quality Control Process?
The article “Are You Integrating TRID into your Quality Control Process?” by Todd Krell and Chris Ortigara, published in California Mortgage Finance News in Summer 2016, discusses the importance of incorporating TRID (TILA-RESPA Integrated Disclosure) into mortgage quality control (QC) processes. While GSEs don’t require TRID reviews, the article stresses that lenders should still audit for TRID compliance to avoid penalties and potential loan refusals from investors. Lenders need to assess factors like past compliance issues and investor expectations to determine the scope of TRID audits. Given TRID’s complexity, with over 140 provisions, lenders must decide whether to review all provisions or just key ones. The authors emphasize that, though TRID reviews can be time-consuming and expensive, the cost of neglecting them could be far greater in the long run.
Best Practices for Establishing a Cost-Effective Internal Audit Function
The article titled “Best Practices for Establishing a Cost-Effective Internal Audit Function” by Heidi Wier, published in Mortgage Compliance Magazine June 2016 issue, provides insights on implementing internal audit in the mortgage industry. Wier discusses how heightened regulatory scrutiny, particularly following the 2008 financial crisis, has pushed both public and non-public mortgage companies to enhance their corporate governance through effective internal audit functions. She highlights the role of internal audits in meeting expectations set by the Consumer Financial Protection Bureau (CFPB), government-sponsored enterprises (GSEs), and other investors, emphasizing the importance of independence and risk management in internal auditing processes.
Internal Audit – Where Does It Fit in the Compliance Puzzle?
The article titled “Internal Audit – Where Does It Fit in the Compliance Puzzle?” by Chris Ortigara and Jim Shankle, published in the January 2016 issue of Mortgage Compliance Magazine, offers a comprehensive guide to understanding the role of the internal audit function in the broader compliance framework. It addresses the confusion mortgage lenders often face in distinguishing between quality control, the Compliance Management System (CMS), and internal audit, especially after the Dodd-Frank Act. The article emphasizes the importance of an independent internal audit function and explores various options for implementing it, from in-house departments to outsourcing, while highlighting the need for a comprehensive, well-documented audit plan to meet Fannie Mae and Consumer Financial Protection Bureau (CFPB) expectations.
