Our professionals have the unique expertise to provide safe, sound, and comprehensive compliance administration services and auditing programs.

SCOPE

• Conduct audit utilizing, in part, federal Interagency procedures and guidelines implemented prior to the effective date of the Rule as well as federal Interagency procedures and guidelines effective after the date of the Rule, as promulgated by the Multi-State Mortgage Committee (MMC) examiner guidelines.

• Completion of Institution Information Request and Institution Questionnaire and Document Request followed by our completion of an Audit Checklist (Interagency), including independent review criteria through documentation review, on-site transaction testing (if required), off-site sampling of transaction documents, and interviews of institution staff or other parties.

REVIEW CONSISTS OF:
  • Report of Findings
  • Review of Policy and Procedures
  • Institution Information Request
  • Institution Questionnaire
  • Document Request
  • Auditing of Sampling Indicia
ANALYSIS

The Loan Originator Compensation review is based on the MMC guidelines, as follows:

Independent review of loan originator compensation using the State Non-depository Examiner Guidelines for Regulation Z - Loan Originator Compensation Rule instituted by the Multi-State Mortgage Committee (MMC), a ten-state representative body created by the Conference of State Bank Supervisors (CSBS) and the American Association of Residential Mortgage Regulators (AARMR).

These are the examiner guidelines that are used as a tool for consistent implementation of the Federal Reserve Board's final rules for closed-end credit under Regulation Z.

METHODOLOGY

Full Scope:
Pre-exam completion of Modules 2 and 3 followed by completion of Module 1 through documentation review, on-site transaction testing, and interviews of institution staff or other parties.

Limited Scope:
Completion of Module 1, excluding transaction testing and interviews, based on the institution's responses to Modules 2 and 3.

Limited Scope with off-site testing:
Combine the Limited Scope approach with an off-site sampling of transaction documents and/or telephone interviews of institution staff or other parties.
  • Module 1 consists of questions intended to guide the examiner for specific review.
  • Much of the checklist can be completed from a thorough, off-site review of the institution's responses to Modules 2 and 3.
  • Other sections require transaction-level interviews of institution staff and others.