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Solutions To Help You Get And Stay Compliant

Compliance Solutions

Our compliance programs are tailored to fit your size or need.

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Compliance Services

Compliance services to meet your needs. From advertising to Reg Z.

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SCP Provides Current Innovation Services

Compliance is a focus of everything we do in our business today. SCP, however, aims to provide more than the protection of attorney driven fixed cost compliance.

Through technological breakthroughs and best in class industry partners, SCP will provide access to multiple services impacting all facets of lending operations.

Important Update – Mini-Correspondent Evaluation

In response to the CFPB’s guidance pertaining to potential treatment of mini-correspondents as brokers and the profound impact on compliance with Regulation Z, RESPA, and ATR laws, SCP in conjunction with Offit Kurman is announcing M-CE: a compliance assessment backed by a legal opinion and analysis to provide Warehouse Lenders, Mini-Correspondents and Investors a third party legal opinion on whether their relationships with Mini-Correspondents will pass CFPB Scrutiny.

The evaluation will also provide recommendations to strengthen the mini-correspondent relationship.

If you are interested in M-CE, register for an M-CE evaluation below or you can contact Leslie Benjamin at lbenjamin@strategiccompliancepartners.com  or phone (301-691-1300) for more information.

M-CE Evaluation

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Strategic Compliance Partners Has The Answer For You!

  • Real-time Policies – Automatically updated, and attorney reviewed based on nationwide audit results.
  • All-encompassing attorney driven compliance programs for lenders of all sizes.
  • Monthly implementation webinars
  • Core compliance training and policy implementation for all staff.
  • Unique solutions provided by cutting edge innovations.
  • I.C.E. Internalized Compliance Examinations.

We Specialize In Financial Services Companies

We specialize in compliance services and solutions for the mortgage banking industry.

Our clients include:

Whether you are a one person mortgage broker or a full service retail lender; we can help you get and remain in compliance. We understand that compliance is not a one size fits all. That is why we are the first in the industry to tailor our compliance solutions to fit the various businesses in our industry.

We utilize and leverage our strategic partnerships with Offit Kurman and other strategic partners to provide a unique combination of experience and backgrounds to find the right compliance solutions for your company.

Whether is merely providing policies that are automatically updated based upon the latest audit findings or providing a fully integrated, turn-key compliance solution, SCP has the most cost-effective and best answers to and options for meeting your compliance needs.

Overview of Compliance Services and Solutions

At SCP we are committed to helping you, your company and the mortgage industry to not only meet the minimum requirements of compliance but to focus on building a better book of business for you, your business, your partners and ultimately the consumer.

SCP Real Time Policies & Training is an online Centralized Compliance Center that includes:

Real Time Policies

SCP Real Time Policies & Training are updated monthly based upon the latest audit findings provided to us by other clients. These findings are reviewed by our compliance counsel and as needed policies are revised, and augmented as needed every month. Through our technology, all a client needs to do is click “accept” and the policies are changed.

The SCP Real Time Policy Guides consist of two separate policy guides:

      • Federal Mortgage Compliance Policy Guide
      • State Mortgage Compliance Policy Guide (additional states may be added for an additional charge)

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SCP Real Time Compliance Training is always kept current in “Real Time”. SCP Real Time includes online compliance training and testing to all employees on the rules and regulations established and enforced by the Consumer Financial Protection Bureau (“CFPB”). Courses included in your SCP Real Time Center include training on Fair Lending, AML, TILA, RESPA, HPA, FCRA/FACT, GLB, Patriot Act, Do Not Call, ECOA, MAPs and the SAFE Act and more!

  • SCP Real Time Training is delivered online and automated
  • Train staff on compliance topics with preloaded courses
  • Anti-Money Laundering (AML), Red Flags, ECOA, HMDA, and more
  • Assign different training to different departments all in your SCP Real Time Dashboard

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SCP Real Time Reporting allows you to:

  • Quickly access online compliance training records for your entire staff
  • Track compliance training by department, course, and compliance status
  • Always up to date. No waiting for reports to compile
  • Receive Automated Compliance Reports sent your email in PDF, CSV, and HTML
  • Customize your email reports to show what you need, when you need it

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  • No installation required
  • Get started immediately
  • Set up and manage your account
  • Upgrades are free and automatic when released
  • Easy Access from Anywhere
  • Employees can access their training, policies and other documents from any device online
  • Mobile friendly website allows employees to take training on the go or in their spare time

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The SCP Customized Training includes a set number of hours of training development time to be used with one of our training developers to help you customize your training.

Strategic Compliance Partners offers several options to help you meet your training needs.

Each course is written and vetted by compliance professionals, attorneys and education specialists.

Courses are delivered as a SCORM compliant course for upload into the company’s existing LMS. Each course will be approximately 30 – 45 minutes and will include an exam at the end of the course.

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The Consumer Financial Protection Bureau (CFPB) notes in its examination guide that Fair Lending Analysis will be part of every examination.

We’re not just talking about CFPB Exams though; many states also are beginning to conduct Fair Lending Analysis as a part of their state audits.

Most companies have never conducted a Fair Lending Analysis of their policies and pricing and may be at risk for Disparate Impact and Fair Lending Violations.

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Strategic Compliance Partners also offers NMLS Continuing Education. Each year we write a new 8 hour NMLS course that will meet the licensure renewal of all state-licensed loan originators.

The NMLS CE can be added to your C3 Real Time package or your Branded Training Center for all of your licensed loan originators to complete on line.

We also sell our NMLS CE as a stand alone online course.

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The SCP TPO Vendor Management program is designed to help companies in the mortgage industry manage their vendor management responsibilities for the service providers they conduct business with.

Who is it for?

The SCP TPO Vendor Management program is for companies who are required to comply with the Vendor Management guidance set out by the CFPB. These companies include:

• Wholesale Lenders
• Mini-Correspondent Lenders
• Correspondent Lenders
• Banks
• Credit Unions
• Appraisal Management Companies
• Title Companies
• Any Service Provider to the Mortgage Industry

What is Included?

The SCP TPO Broker Renewal

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With SCP Compliance Coach you pay upfront for a limited number of hours that you can have access to one of our compliance specialists.

Compliance Coach is not a replacement for legal advice; nor is it meant to be used as such. SCP Compliance Coach is just that; coaching from a compliance specialist.

Advisory Services

With SCP Advisory Services, you have access to a compliance team consisting of an experienced compliance specialist and an attorney, You pay a an upfront team rate for a limited number of hours you can use for compliance related services overseen by our affiliated attorneys available through Offit Kurman. Although it’s not legal advice, your compliance team will give you the dual perspective of a practicing attorney and the practical feedback from a compliance specialist.

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The SCP Training Center is branded to your company with your logo. You receive your own unique URL to post on your intranet for your employees to easily access for training.

Complete Compliance Course Curriculum

The SCP Branded Training Center comes with more than 20 compliance courses for you to easily assign to your staff. Courses on Fair Lending, Anti-money Laundering, RESPA, TILA, ECOA, Advertising Compliance and more are just a few of the courses you can easily assign to your staff.

Each course is written and vetted by compliance professionals, attorneys and education specialists. Courses automatically included in your SCP Branded Training Center. Each course will be approximately 30 – 45 minutes and will include an exam at the end of the course.

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Frequently Asked Questions

How do you comply with the ATR requirements?

The ATR rule is satisfied by meeting the specific ATR requirements, i.e., the list of eight (8) underwriting factors to consider, are:

(1) current or reasonably expected income or assets;
(2) current employment status;
(3) monthly payment on covered transactions;
(4) monthly payment on any simultaneous loan;
(5) monthly payment for mortgage-related obligations;
(6) current debt obligations, alimony, and child support;
(7) the monthly debt-to-income ratio or residual income;
(8) credit history.

Under the ATR rule, am I still allowed to originate a mortgage with a DTI higher than 43%?

Yes, the 43% DTI ratio, which under the regulation is the back-end ratio, applies to QMs but, even under the QM definition; there is not an absolute bar on back-end ratios above 43%.

If a loan qualifies for purchase by a sponsored GSE or for insurance or sponsorship by a federal agency the loan is eligible for QM status.

However, the GSE/federal agency test is limited in duration and, in particular, the federal agency test is limited to the federal agencies promulgating their own QM test—HUD proposed its QM definition on September 30, 2013.

What is the difference between a Safe Harbor and Rebuttable Presumption QM?

The difference between a Safe Harbor QM and a rebuttable presumption QM is the level of protection afforded the lender.

A Safe Harbor QM conclusively establishes that the lender complied with the ATR requirements when originating the mortgage; on the other hand, the rebuttable presumption allows the consumer to argue, i.e., rebut, that the lender properly evaluated the consumer’s ability-to-repay at the time of consummation.

Rebuttable presumption QMs definition is as a QM loan with an APR that is 1.5 percentage points above the APR, i.e., a Higher-Priced Mortgage loan.

What specific fees are included in the QM points and fees calculation?

The points and fees calculation is complex. The CFPB did not provide a specific GFE or HUD-1 line by line inclusion or exclusion of fees.

Instead, the CFPB provided categories of fees that should be included in the QM points and fees calculation.

Those categories are:

1) Loan Originator Compensation;
2) Non-Interest Finance Charges;
3) Loan Level Price Adjustments (if not built into pricing)
4) premiums for insurance where the creditor is the beneficiary or debt cancellation or suspension coverage payment payable at or before consummation;
5) PMI premiums payable at or before consummation that exceed the FHA premium or are not required to be refunded when the loan is paid in full;
6) prepayment penalties if the lender is refinancing a loan held by or serviced by the lender or an affiliate.

What features are prohibited for QM loans?

Generally, loans that have the following characteristics are not considered QM loans: Negative amortization; Interest-only payments; Balloon payments; Terms exceeding 30 years; or No doc loans.

Who is a considered a loan originator under the revised rule?

The expanded definition of loan originator includes anyone who takes applications; offers, arranges, or assists in obtaining or applying to obtain credit; advertises or communicates to the public that they can or will perform any loan origination activities; or who offers or negotiates credit terms.

Does the new definition of loan originator encompass processors and underwriters activities?

Engaging in normal processing and/or underwriting activities does not meet the definition of loan originator. However, communication of the actual credit offer, taking of an application, or discussion of specific terms of credit—including making a counter-offer— would meet the definition of loan originator.

Does telemarketing count as originating even if an application is not taken?

More Specifically: My Company conducts telemarketing activity where a sales assistant hands-off “hot leads” to a licensed MLO, does this activity count as originating even if the sales assistant does not take an application?

Under the definition of loan originator, telemarketers or anyone participating in the origination process likely meets the definition.

This fact has far-reaching implications, and a company should review all position descriptions in order to evaluate whether that particular position’s requirements meet the definition of loan originator.

If it does, the company should review the employee compensation plan to ensure it meets the requirements under the Final Rule and determine whether the employee meets the qualification and background requirements required for loan originator employees, which can be found here:


Can a company still have non-producing branch managers?

Yes, but SCP does not recommend this approach. Technically, as long as the origination of loans is not the basis for the manager’s compensation, and the branch manager does not communicate specific credit terms or engage in offer/counter-offer negotiations with the consumer, they will not meet the definition of loan originator and be subject to LO Compensation rules.

It is important to remember that constructing a compensation plan and position description that meets the LO Compensation rules is a complex undertaking.

SCP recommends engaging legal counsel if you wish to have non-producing branch managers.

How do I make sure I am compliant with the new LO Comp rules?

Complying with the new loan originator compensation rules requires revising job descriptions so that no gray areas exist, structuring compensation arrangements accordingly (especially in regards to management compensation), and making all bonuses easily traceable and verifiable.

Remember, compliance is about viewing your company’s practices through the regulator’s lens, and the CFPB’s lens places consumer protection above all else. SCP recommends having all employment agreements drafted or reviewed by an attorney.

Do we have to establish an escrow account moving forward if my company qualifies for the small creditor exemption?

Not necessarily, if your organization originates a loan under a forward commitment and the acquirer of the loan is not eligible for the exemption, you must establish an escrow account.

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