CFPB Examination Procedures – Mortgage Origination

 These Mortgage Origination Examination Procedures (“Procedures”) consist of modules covering the various elements of the mortgage origination process; each module identifies specific matters for review. Examiners will use the Procedures in examinations of mortgage brokers and mortgage lenders, generally called “mortgage originators” in these procedures. Before using the Procedures, examiners should complete a risk assessment and examination scope memorandum in accordance with general CFPB procedures. Depending on the scope, and in conjunction with the compliance management system review, including consumer complaint review, each examination will cover one or more of the following modules:

                          Module 1 Company Business Model

                          Module 2 Advertising and Marketing

                          Module 3 Loan Disclosures and Terms

                          Module 4 Underwriting, Appraisals, and Originator Compensation

                          Module 5 Closing

                          Module 6 Fair Lending

                         Module 7 Privacy

 Examination Objectives

  1. To assess the quality of a supervised entity’s compliance management systems in its mortgage origination business.
  2. To identify acts or practices that materially increases the risk of violations of federal consumer financial law, and associated harm to consumers, in connection with mortgage origination.
  3. To gather facts that help determine whether a supervised entity engages in acts or practices that are likely to violate federal consumer financial law in connection with mortgage origination.
  4. To determine, in accordance with CFPB internal consultation requirements, whether a violation of a federal consumer financial law has occurred and whether further supervisory or enforcement actions are appropriate.

Arrange a Pre-Examination Assessment and correct any compliance or operational issues before the Regulators show up on your doorstep.

Contact Penny Showalter at pshowalter@cognops.com to discuss what you need.