What to Fix Before Summer Exams

Summer exam season has a pattern: it starts quietly, and then timelines accelerate quickly. By the time many brokerages receive notice, there’s limited time to correct issues—and even less room for error.

The most successful exam outcomes don’t come from last-minute fixes. They come from early, targeted reviews that focus on the areas regulators consistently evaluate.

Below are the key areas to address before exam notices arrive.

1. Incomplete Documentation

One of the most common—and avoidable—issues during exams is incomplete documentation.

In many cases, brokerages are following the right processes operationally. However, without clear records, there is no way to demonstrate that compliance standards are being met. Examiners rely on documentation, not intent.

This includes:

  • Missing or inconsistent file records
  • Lack of audit trails for decisions or reviews
  • Gaps in tracking internal processes

A strong documentation structure should make it easy to show what was done, when it was done, and who was responsible.

2. Outdated Policies

Policies are expected to reflect how your brokerage operates today—not how it operated when they were first written.

As teams grow, processes evolve, and new tools are introduced, policies often fall behind. This creates a disconnect that regulators quickly identify.

Common issues include:

  • Policies that don’t match current workflows
  • Missing updates for new regulatory expectations
  • Inconsistent application across branches or teams

Regular policy reviews ensure alignment between written procedures and actual business practices.

3. Training Gaps

Training is a key focus area during exams, but it’s not just about completion—it’s about proof and consistency.

Even when training is conducted, issues arise when:

  • Completion records are missing or incomplete
  • Training is not tracked across all team members
  • There is no clear schedule or structure

Examiners will look for documented evidence that required training is completed, up to date, and consistently applied across the organization.

4. Advertising Approvals

Marketing and advertising continue to be heavily scrutinized in exams. Small inconsistencies can quickly turn into findings if proper controls aren’t in place.

Areas to review include:

  • Approval processes for all marketing materials
  • Required disclosures and licensing information
  • Consistency across platforms and loan officer activity

Reused or outdated ads, missing approvals, and decentralized marketing efforts are common sources of risk.

Why Early Preparation Matters

Once an exam notice is received, timelines become compressed. Fixing documentation gaps, updating policies, or reconstructing records under pressure is far more difficult than addressing them proactively.

A structured pre-exam review allows brokerages to:

  • Identify and correct issues early
  • Reduce last-minute stress and disruption
  • Present a more organized, compliant operation during exams

Preparation isn’t about overhauling everything—it’s about tightening the areas that matter most.

Be Ready Before the Notice Arrives

Summer exams don’t wait for perfect timing. Being prepared ahead of time gives your brokerage the ability to respond confidently, rather than react under pressure.

SCP helps brokers prepare for exams with focused, efficient reviews that identify gaps early—so you’re ready before regulators step in.

If you’re approaching exam season, now is the time to act. Reach out to SCP to run a pre-exam check and ensure your documentation, policies, training, and advertising are fully aligned before notices arrive.

Don’t wait for renewal issues to surface. Make the right adjustments now and stay ahead.

Contact SCP at sales@strategiccompliancepartners.com or call 301.578.6015 to clean up gaps before they become problems.

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About Ari Karen

Ari Karen is an experienced litigator who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide. Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others.

Mr. Karen speaks regularly on topics affecting all types of lenders including fair lending and disparate impact, LO compensation, marketing service agreements, compliance with social media, non QM lending, vendor management, and much more. Mr. Karen is a principal in the Financial Institutions Regulatory and Labor and Employment practice groups of the Offit Kurman law firm.