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Ideas in Action


Cognitive Options conducts Regulatory Compliance reviews that provide our clients insight as to why loans may or may not meet the requirements of Federal, State, County, Local High Cost and Anti-Predatory Laws.  Our compliance review includes the following:

  • State High Cost and Higher Priced Mortgage Loans
  • HPML / Section 32 HOEPA including APR and Points and Fees
  • Ability to Repay – 8 Components of ATR
  • Qualified Mortgages (QM and Temporary QM)
  • TILA / MDIA / RESPA
  • HMDA
  • National Flood Insurance Act
  • Escrow and Appraisal requirements
  • TRID Post Closing Due Diligence & Compliance Review:
  • The correct information is disclosed on the loan estimate
  • Loan estimate was provided to the borrower within the correct amount of days from application
  • TRID disclosures were provided to the borrower within the correct amount of time from application
  • All required TRID disclosures were provided to the borrower(s)/consumer(s)
  • Changed circumstance audit; change type is consistent with the reason; re-disclosed loan estimates were issued within the required amount of days of the changed circumstance
  • Loan terms on the loan estimate is consistent with the loan terms on the closing disclosure
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