Core Compliance Solutions
SCP Core Compliance includes the following services:
1. SCP Initial Assessment
SCP will schedule an initial assessment that will review compliance with Federal and State lending laws concerning:
Following the initial assessment, SCP will develop a customized compliance including specific recommendations and an implementation plan and a schedule for monitoring, adherence to the plan and meeting quarterly with the Compliance Officer and/or Board of Directors on to report on progress and any changes to the plan, as well as address new challenges or issues.
3. Policies and Procedures
Review, revision and/or development of policies, and assist in the creation and implementation of policy consistent practices (as applicable) pertaining to:
The policy guides will consist of two separate policy guides:
> Federal Mortgage Compliance Policy Guide
> State Mortgage Compliance Policy Guide
On a monthly basis, we will review audit results from clients with similar policies. SCP’s team will meet with compliance counsel and recommend changing or updating policies based upon these actual audit results. Policies will be developed/amended and updates supplied on an as needed basis, depending upon the recommendations of SCP compliance specialists and legal counsel.
The Federal Mortgage Compliance Policy Guide will include applicable Federal Consumer Protection Regulations as they relate to your business practices.
As scheduled, SCP will meet with the Compliance Officer and Board of Directors on a quarterly basis to provide ongoing assessment of the recommendations and implementation plan as well as address new challenges or issues. SCP will also provide support and needed assistance in regard to fair lending monitoring and analysis of QC reports on a quarterly basis.
4. Monitoring and Updates
Client will have a customized monitoring program including at least quarterly (if not more often) meetings with high level management. Clients will receive monthly compliance updates as to compliance developments and will also be able to participate in monthly compliance calls. In addition, Compliance team will check in with Client at least weekly.
5. Pre-audit/Exam Preparations and Assistance
Pre-audit/exam preparations and assistance for one scheduled standard Federal (CFPB, FDIC, OCC or FRB) Supervisory Compliance Exam/Audit. The pre-audit/exam preparation and assistance will include 10 hours on-site and an additional 10 hours off-site of audit/exam preparation/assistance, within the Standard Regulatory Services. Additional time needed or requested in connection with pre-audit/exam preparation and assistance will be billed hourly.
6. Fair Lending
Will assist in providing data for fair lending regression analysis and perform an analysis 1x per on a pricing and underwriting first level analysis. Will provide interpretations, recommendations, and necessary policies, procedures and training. Volume in excess of 2500 loans may involve additional fees.
7. Agency Audits Plans and Procedures
8. Compliance Officer Support Services
To assist in the compliance implementation plan, you will have the use of your compliance team up to 10 hours per quarter (on a use it or lose it basis). In addition to general questions and assistance, the support services can address questions and/or provide assistance with any compliance matters. In response to inquiries, your SCP Compliance Team will respond to inquiries within 24 hours generally. Once the 40 support hours has been exhausted, support services will be billed at $235 per hour.
10. Fee Arrangement
The standard pricing for the SCP Core Compliance Program is for a 12-month period. Monthly Fee is $3,425 per month. $40 per month for each additional state policy beyond the one state policy guide which is included in this package. $10 per employee one-time fee for training (not applicable to staff already enrolled in training). Depending on volume may require an additional fee for outsourced regression analysis if above 2500 loans annually. If lenders want to perform regression analysis on their own, above monthly price is subject to 3.5% reduction.