Completing Your Compliance Management System

Simply having written policies and procedures is not a compliance management system. The key word here is “management”. Compliance management means tracking specific details within every regulation and validating implementation.

Indecomm-Mortgage U’s Health Check is your compliance management tool. The key benefit to the Health Check service is the IMU team of compliance experts tracking existing and new regulations, determining how the rules impact day to day requirements and providing input to subscribing companies about our research and analytics. As an internal tool companies can see clearly where gaps must be filled before an auditor does. The checklist, which is updated whenever the regulations change, generates various reports to show team members, auditors and executives the work in progress and completed. Compliance is never finished. Interpretations are constant and the Health Check manages the chaos for you.

Here is a sample of the support we offer continuously to our subscribers:

Client: Our company closes and funds our mortgages but we do not sell directly to FannieMae or FreddieMac; we sell to other investors. How do we report the purchaser correctly on the HMDA LAR?
Health Check Response: You must report the correct code for the purchaser of the mortgage on the HMDA LAR. Look in Appendix A of “HMDA-Getting it Right”, Section E, for the Type of Purchaser codes to use. As an example, if the investor is a commercial bank you would choose Code 6, but if it is a credit union you would use Code 7. If the investor is a privately-held investment company the correct code would be Code 9, “Other type of purchaser”.

Client: If there are multiple versions of an appraisal is it necessary to give copies of all versions to the applicant?
Health Check Response: Under ECOA, you must deliver copies of appraisals (all valuations) for covered loans “promptly upon completion” or within three business days before closing, whichever is earlier. If you get multiple versions you need only give the latest version. If another version is made later you must also provide a copy of that version.

Under TILA, if a loan is an HPML, you must deliver copies of all appraisals three business days prior to closing. There is no stipulation in the regulation for providing only the latest version.

Click here to find out more about Health Check.