Comprehensive Mortgage Policies

Mortgage Mindset Core Policies

Fair Lending and Non-Discrimination Policies

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

Risk Management

Risk Management Policy: Framework for identifying, assessing, and mitigating organizational and operational risks

Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) Policies

Customer Identification Policy: Requires verification of borrower identities using government-issued IDs
Suspicious Activity Reporting Policy: Outlines procedures for filing Suspicious Activity Reports (SARs) with FinCEN
AML/BSA Training Policy: Mandates annual employee training on AML/BSA requirements
AML Audit Policy: Requires independent audits of AML compliance and recordkeeping

Loan Origination Policies

Loan Application Policy: Details procedures for accepting and processing applications, including required documentation and timelines
Borrower Verification Policy: Outlines steps for verifying income, assets, credit, and employment, per investor and regulatory standards Underwriting Policy
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
TRID Disclosure Policy: Ensures timely delivery of Loan Estimates (LE) and Closing Disclosures (CD) per TILA-RESPA Integrated Disclosure (TRID) rules
Fair Lending Policy: Prohibits discrimination and ensures equal treatment under ECOA and Fair Housing Act, with monitoring procedures
Loan Denial Policy: Governs the process for denying or withdrawing applications, including issuing Adverse Action Notices within 30 days
Appraisal Management Policy: Ensures compliance with appraisal independence requirements (Regulation Z, § 1026.42)

Quality Control (QC) Plan

Post-Closing QC Policy: Mandates audits of closed loans to ensure adherence to investor and regulatory guidelines
QC Sampling Policy: Defines methodology for selecting loans for review (e.g., 10% or statistically significant sample)
QC Reporting Policy: Requires regular reports to management and regulators on audit findings and corrective actions

Responsible Lending Policies

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

Disclosure and Consumer Information Policies

Loan Estimate Policy: Mandates issuance of Loan Estimates within three days of application (TRID)
Closing Disclosure Policy: Ensures delivery of Closing Disclosures at least three days before closing (TRID)

IT, Systems & Vendor Governance

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