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  • Home
  • Mortgage Policies
  • Technology Consulting
  • BPO Implementation
  • Risk Reduction&Compliance
  • Process Improvement

Mortgage Mindset Core Policies

Please reach us at ross.wroblewski@yahoo.com if you cannot find an answer to your question.

  1. CMS Governance Policy: Defines roles, responsibilities, and oversight structure for compliance management, including a compliance officer and committee
  2. Regulatory Monitoring Policy: Outlines procedures for tracking and implementing federal and state regulatory changes (e.g., CFPB updates, TILA, RESPA)
  3. Compliance Training Policy: Mandates regular employee training on laws, regulations, and company policies, with documentation of completion
  4. Compliance Auditing Policy: Details internal and external audit schedules, scope, and corrective action processes for identified issues
  5. Complaint Management Policy: Establishes procedures for receiving, investigating, and resolving consumer complaints, including timelines and regulatory reporting
  6. Third-Party Vendor Compliance Policy: Governs oversight of vendors to ensure their compliance with applicable laws
  7. Compliance with Regulatory Requirements Policy: Adhering to industry regulations like TILA, RESPA, and state laws protects the business from legal penalties and enhances trust with clients and regulators

  1. Loan Application Policy: Details procedures for accepting and processing applications, including required documentation and timelines
  2. Borrower Verification Policy: Outlines steps for verifying income, assets, credit, and employment, per investor and regulatory standards Underwriting Policy
  3. Underwriting Policy: Specifies guidelines for loan approval, aligned with Fannie Mae, Freddie Mac, FHA, VA, or USDA requirements, including debt-to-income (DTI) and loan-to-value (LTV) ratios
  4. TRID Disclosure Policy: Ensures timely delivery of Loan Estimates (LE) and Closing Disclosures (CD) per TILA-RESPA Integrated Disclosure (TRID) rules
  5. Fair Lending Policy: Prohibits discrimination and ensures equal treatment under ECOA and Fair Housing Act, with monitoring procedures
  6. Loan Denial Policy: Governs the process for denying or withdrawing applications, including issuing Adverse Action Notices within 30 days
  7. Appraisal Management Policy: Ensures compliance with appraisal independence requirements (Regulation Z, § 1026.42)

  1. Payment Processing Policy: Details procedures for processing payments, applying funds, and handling partial payments (§ 1026.36)
  2. Periodic Statement Policy: Ensures delivery of accurate periodic statements per Regulation Z (§ 1026.41)
  3. Escrow Account Policy: Governs management of escrow accounts for taxes and insurance, including annual analysis (§ 1024.17)
  4. Error Resolution Policy: Outlines steps for addressing borrower-reported errors within mandated timelines (§ 1024.35)
  5. Information Request Policy: Specifies handling of borrower requests for information (§ 1024.36)
  6. Early Intervention Policy: Mandates contact with delinquent borrowers within 36 days of delinquency (§ 1024.39)
  7. Loss Mitigation Policy: Details procedures for evaluating and offering foreclosure alternatives, like modifications or forbearance (§ 1024.41)
  8. Servicing Transfer Policy: Ensures smooth transfer of servicing rights without disruption to borrowers.

  1. Pre-Funding QC Policy: Requires audits of loan applications before closing to verify data accuracy and compliance
  2. Post-Closing QC Policy: Mandates audits of closed loans to ensure adherence to investor and regulatory guidelines
  3. QC Sampling Policy: Defines methodology for selecting loans for review (e.g., 10% or statistically significant sample)
  4. Defect Resolution Policy: Outlines steps for correcting identified issues, including re-underwriting or borrower notifications
  5. QC Reporting Policy: Requires regular reports to management and regulators on audit findings and corrective actions

  1. Fraud Red Flags Policy: Identifies indicators of fraud (e.g., falsified documents, straw buyers) and escalation procedures
  2. Identity Theft Prevention Policy: Implements a program to detect, prevent, and mitigate identity theft per FACTA
  3. Fraud Reporting Policy: Details requirements for reporting suspected fraud to regulators or law enforcement
  4. Fraud Training Policy: Mandates employee training on recognizing and addressing fraud risks.
  5. Insider Threat Policy: Mitigates risks from individuals within the organization who could intentionally or unintentionally cause harm

  1. Customer Identification Policy: Requires verification of borrower identities using government-issued IDs
  2. Suspicious Activity Reporting Policy: Outlines procedures for filing Suspicious Activity Reports (SARs) with FinCEN
  3. AML/BSA Training Policy: Mandates annual employee training on AML/BSA requirements
  4. AML Audit Policy: Requires independent audits of AML compliance and recordkeeping.
  5. Risk Management Policy: Framework for identifying, assessing, and mitigating organizational and operational risks

  1. Affordability Assessment Policy: Requires evaluation of borrower DTI, residual income, and ability to repay (ATR) per Regulation Z (§ 1026.43)
  2. Adjustable-Rate Mortgage (ARM) Policy: Mandates consideration of future rate increases in affordability assessments
  3. Anti-Predatory Lending Policy: Prohibits steering borrowers to unaffordable or unsuitable loans
  4. Business-Purpose Loan Policy: Governs loans exempt from certain consumer protections, if applicable.

  1. GLBA Safeguards Policy: Ensures protection of nonpublic personal information per Gramm-Leach-Bliley Act
  2. Data Breach Response Policy: Outlines steps for responding to and reporting data breaches
  3. Data Security Policy: Specifies secure storage, encryption, and transmission of sensitive data
  4. Employee Access Control Policy: Limits access to borrower data based on job function
  5. Access Control Policy: Defines who can access what systems and data — essential for preventing unauthorized use or data breaches
  6. Audit Logging & Monitoring: Tracks activity across systems, enabling early detection of anomalies or threats
  7. Cryptography Policy: Ensures that sensitive information (like client financial data) is encrypted, both in transit and at rest
  8. Data Security and Privacy Policy: Mortgage firms handle highly sensitive client data. Strong privacy practices help avoid data breaches, regulatory fines, and damage to reputation
  9. Information Security Policy (AUP): Establishes acceptable use of company systems and data — protecting against careless or malicious misuse
  10. Information Security Roles and Responsibilities: Clarifies who owns security functions, ensuring accountability and consistent enforcement
  11. Privacy & Data Protection: Demonstrates a legal and ethical commitment to protecting client and employee personal data — crucial in financial services

  1. Non-Discrimination Policy: Prohibits discrimination based on protected characteristics under ECOA and Fair Housing Act
  2. Fair Lending Monitoring Policy: Requires regular analysis of lending patterns for potential disparities
  3. Fair Lending Training Policy: Mandates employee training on fair lending principles
  4. Discrimination Complaint Policy: Details procedures for handling and resolving discrimination complaints

  1. MARS Disclosure Policy: Requires clear disclosures in advertisements and communications per FTC’s MARS Rule
  2. Upfront Fee Prohibition Policy: Prohibits collecting fees before services are rendered
  3. Attorney Exemption Policy: Governs compliance for attorney-based services, if applicable

  1. Employee Conduct Policy: Outlines expectations for professionalism, confidentiality, and conflicts of interest
  2. Branch Operations Policy: Details setup, management, and oversight of branch offices
  3. Vendor Management Policy: Governs selection, monitoring, and termination of third-party vendors
  4. Facility Management Policy: Addresses physical plant maintenance, security, and supplies

  1. Loan Estimate Policy: Mandates issuance of Loan Estimates within three days of application (TRID)
  2. Closing Disclosure Policy: Ensures delivery of Closing Disclosures at least three days before closing (TRID)
  3. Periodic Statement Disclosure Policy: Governs delivery of servicing statements (§ 1026.41)
  4. Housing Counselor List Policy: Requires providing lists of HUD-approved housing counselors for certain loans
  5. Early Intervention Disclosure Policy: Mandates notices to delinquent borrowers (§ 1024.39)

  1. Escrow Analysis Policy: Requires annual analysis to adjust escrow payments (§ 1024.17)
  2. Escrow Shortage/Surplus Policy: Details handling of escrow account shortages or surpluses
  3. Forced-Placed Insurance Policy: Governs placement of insurance when borrowers fail to maintain coverage (§ 1024.37)
  4. Escrow Disclosure Policy: Ensures proper disclosures for escrow accounts (§ 1024.17)

  1. High-Cost Mortgage Identification Policy: Defines criteria for identifying HOEPA loans (e.g., APR or points/fees thresholds)
  2. High-Cost Mortgage Restriction Policy: Prohibits certain terms (e.g., balloon payments) for HOEPA loans
  3. Homeownership Counseling Policy: Mandates counseling for high-cost mortgage applicants

  1. Loan File Retention Policy: Requires retention of loan files for at least three years (or longer per state law)
  2. HMDA Reporting Policy: Governs collection and submission of Home Mortgage Disclosure Act data
  3. Compliance Recordkeeping Policy: Mandates documentation of audits, training, and complaint resolutions
  4. Regulatory Examination Policy: Outlines procedures for preparing for and responding to regulatory exams

  1. Change Management: Manages process and system changes to avoid disruptions or the introduction of security gaps
  2. Configuration Management: Standardizes and secures system setups, reducing vulnerability from misconfigurations
  3. Procurement & Vendor Risk: Reduces exposure to risk introduced by third-party vendors or services
  4. Secure Development Policy: Ensures new systems, workflows, or automations are developed with security embedded
  5. Third-Party Management Policy: Formalizes selection, monitoring, and offboarding of external partners — especially critical when clients’ systems are involved

Additional Policies to Consider

  1. Accounts Receivable and Collections Policy: Efficient invoicing and follow-up processes improve cash flow, reduce bad debt, and keep the business financially stable—vital for small firms reliant on consistent client payments
  2. Billing and Invoicing Policy: Standardizes how and when clients are billed to ensure consistency, reduce payment delays, and support healthy cash flow
  3. Budgeting and Forecasting Policy: Forecasting and budgeting allow the firm to plan for growth, allocate resources wisely, and navigate market volatility such as shifts in interest rates or housing demand
  4. Cash Management Policy: Maintaining liquidity ensures that the firm can meet obligations during low revenue periods and improves financial decision-making through regular monitoring of cash flows
  5. Client Retainer and Prepayment Policy: Clarifies how upfront payments are recorded and managed to ensure accurate revenue recognition and client protection
  6. Expense Tracking and Reimbursement Policy: Properly tracking and categorizing business expenses supports accurate financial reports, maximizes tax deductions, and ensures consultants are reimbursed fairly for work-related costs
  7. Financial Reporting Policy: Establishes routine preparation of financial statements to improve decision-making, transparency, and tax compliance
  8. Grants, Subsidies, and Incentive Tracking Policy: Ensures external funding is properly tracked and reported to maintain compliance and maximize available financial support
  9. Internal Audit and Financial Review Policy: Regular audits and reviews safeguard the integrity of financial records, identify issues early, and provide insights to improve operational efficiency and financial health
  10. Investment and Reserve Policy: Guides management of surplus funds to maintain liquidity and financial stability while allowing for strategic growth
  11. Payroll and Compensation Policy Clear payroll procedures reduce compliance risks with labor and tax laws, while defined commission structures ensure transparency and trust with consultants and employees
  12. Revenue Recognition Policy: Accurately timing when revenue is recorded ensures compliance with financial reporting standards (GAAP/IFRS) and prevents overstating income. This is especially critical for mortgage consultants whose income is often tied to contingent events like closings
  13. Segregation of Duties Policy: Separating financial responsibilities reduces the risk of fraud or errors by ensuring no single person has full control over any one financial process (e.g., billing, payments, reconciliation).
  14. Travel and Entertainment Policy: Controls business-related travel and client entertainment spending to prevent misuse and support tax deductibility

  1. Business Continuity & Disaster Recovery Plan: Ensures the company can recover quickly from outages or crises with minimal disruption to clients
  2. Incident Response Plan: Provides a structured approach to responding to cybersecurity incidents or data breaches

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