How will eased regulations affect lenders? Homeowners? What reforms are ahead for the CFPB? Will it be dismantled? Without a doubt, the mortgage industry is undergoing major changes. It remains to be seen what the long-term effects will be, yet one thing is certain — today, there’s a great deal of confusion and lack of clarity from the ever-changing mortgage lending landscape.
For Compliance Officers, however, it’s business as usual, charged with ensuring they keep the mortgage lender compliant, reputable and financially healthy. Generally speaking, the Compliance Officer is responsible for two areas: compliance with external rules imposed upon the organization, and compliance with internal systems, such as policies and practices imposed by management in order to achieve compliance of external rules. More specifically, the Compliance Officer must:
1. Gain and maintain a thorough understanding of current requirements, potential changes and the effect on management, staff and operations. Be prepared to act swiftly with changes to policy, process, reporting and training.
2. Develop internal policies, procedures, and controls to ensure compliance with all origination regulations. Keep written documentation available for employees that covers company policy on anti-money laundering and other topics.
3. Manage implementation of regulatory changes and develop a monitoring and testing plan to ensure compliance.
4. Ensure advertising and marketing are compliant with federal and state advertising regulations and rules. Develop and maintain a review and approval process for all marketing to comply with record retention requirements and to ensure evidence of RESPA compliance when co-marketing.
5. Keep all staff constantly in the loop regarding federal and state regulatory changes as well as investor and internal policy changes. Maintain a record of these communications. A well-informed, up-to-date, staff helps reduce the number of problem loans sent back to be reworked, as well as penalties due to non-compliance.
While there is a heavy burden placed on the Compliance Officer, there is good news. Strategic Compliance Partners (SCP) helps facilitate these responsibilities. At a fraction of the cost of hiring a full-time compliance employee, lenders can retain the services of a team of dedicated compliance professionals, which include experienced compliance personnel and compliance attorneys.
Among our many services is “SCP Onsite Compliance,” a comprehensive compliance management system that brings an SCP consultant to your location. SCP will recruit, hire, train and oversee an Onsite Compliance Officer, who in conjunction with SCP consultants, will perform the functions of a Chief Compliance Officer. We’ll also bear all costs of health insurance, E&O coverage, social security, and all other employment-related taxes and costs of the Onsite Compliance Officer.
The bottom line? SCP Onsite Compliance helps save the cost of a full-time Compliance Officer and ensures these imperatives are firmly in place, at all times.