SMC 1: "A Corp"
Case Overview
States Licensed: 25
Branches: 65
Loan Officers: 450
Origination is through “boots-on-the-ground” branch network. Expansion is accomplished by acquiring smaller shops and transitioning them into branches of “A Corp”. Branches have great latitude to use prior branding as well as individual marketing. “A Corp” also employs Loan Officer Assistants who have NMLS numbers but are not licensed to originate.
Branch Managers are responsible for compliance. “A Corp” has 10 Regional Managers who are responsible for groups of Branches. Each Branch has a Marketing Assistant who is responsible for helping with Loan Officer marketing. State regulatory audits have disclosed a large number of violations of marketing on line. Also, it appears that some LOAs are also marketing. The Compliance Department is responsible for social media compliance, among many other responsibilities and needs to get a handle on this and is looking for solutions.
AcuClix Solution:
Social Media Compliance Review
· AcuClix will review each Loan Officer once per year, approximately 45/month.
· AcuClix will review each Loan Officer Assistant ("LOA") once per year.
· AcuClix will review new Loan Officers/LOAs in each Branch within 30 days of on-boarding.
Reporting
· AcuClix will provide an Excel spreadsheet Report of the findings, sites and other data sorted by Loan Officer/Branch, Branch Marketing Assistant and Regional Manager.
· This Report is forwarded monthly to the Compliance Manager.
· The Compliance Manager reviews the Report and forwards to appropriate Regional Managerswho follows up with the Branch Marketing Assistant who are responsible for making changes.
Implementation
· Training and support are provided, as requested, through live on-line meetings and recorded training videos.
· Set up within a period of three weeks.
· AcuClix provides quarterly training sessions to Branch Marketing Assistants.
Certification
· Because AcuClix is doing reviews, A Corp will receive a written “Certification of Social Media Compliance” statement annually. This Certification is used by A Corp for regulatory audits.
SMC 2: “B Corp”
Case Overview
States Licensed: 5
Branches: 5
Loan Officers: 150
Origination is “boots-on-the ground” “B Corp” is expanding by hiring individual Loan Officers. “B Corp” requires all Loan Officers to use its brand and does not allow for independent marketing.
“B Corp” has hired a new Compliance Assistant. She is responsible for social media compliance and reports to the Compliance Manager. She is looking for a solution.
AcuClix Solution:
Social Media Compliance Review
· AcuClix will review each Loan Officer once per year, approximately 15/month;
· AcuClix will review new Loan Officers within 60 days of on-boarding.
Reporting
· Reports are forwarded directly to the Compliance Assistant.
· The Compliance Assistant reviews the Report and forwards to Loan Officer.
· Compliance Assistant follows up with Loan Officer for changes and corrections.
Implementation
· Training and support are provided, as requested, through live on-line meetings and recorded training videos.
· Set up within a period of three weeks.
Certification
· Because AcuClix is doing reviews, “B Corp” will receive a written “Certification of Social Media Compliance” statement annually. This Certification is used for regulatory audits.
SMC 3: “C Corp”
Case Overview
States Licensed: 10
Branches: 2
Loan Officers: 135
Origination is done with two call-centers and expansion is accomplished by hiring individual MLOs. Loan Officers do not market individually.
The Compliance department is responsible for social media compliance, among many other responsibilities. The existing policy is that Loan Officers are not allowed to use the internet for marketing or promotion of the business. The Compliance VP wants to determine if Loan Officers are following policy.
All leads are provided through direct marketing by “C Corp”.
AcuClix Solution:
Social Media Compliance Review
· AcuClix will review each Loan Officer once per year.
· All reviews done at one time.
Reporting
· AcuClix will provide an Excel spreadsheet Report of the findings, sites and other data.
· This Report is forwarded upon completion to the Compliance VP.
Implementation
· Training and support are provided, as requested, through live on-line meetings and recorded training videos.
· Set up within a period of three weeks.
Certification
· Because AcuClix is doing reviews, “C Corp” will receive a written “Certification of Social Media Compliance” statement annually. This Certification is used for regulatory audits.
SMC 3: “D Corp”
Case Overview
States Licensed: 5
Branches: 4
Loan Officers: 75
Origination is “boots-on-the-ground” and expansion is accomplished by hiring individual MLOs. “D Corp” has hired a new Compliance Manager and one of her major tasks is to create and implement a social media compliance policy. She wants to know what is going on with her Loan Officers right now to help with this plan.
AcuClix Solution:
Social Media Compliance Review
· AcuClix does a full review of all 75 Loan Officers.
· AcuClix, thereafter, review each Loan Officer once per year, 8/month.
· AcuClix will review new Loan Officers within 60 days of on-boarding.
Reporting
· AcuClix will provide an Excel spreadsheet Report of the findings, sites and other data.
· This Report is forwarded upon completion to the Compliance Manager.
· Thereafter, reports forwarded on flow basis to Compliance Dept for follow up.
Implementation
· Training and support are provided, as requested, through live on-line meetings and recorded training videos.
· AcuClix will assist with the creation and review of Social Media Policy.
· Set up within a period of three weeks.
Certification
· Because AcuClix is doing reviews, “D Corp” will receive a written “Certification of Social Media Compliance” statement annually. This Certification is used for regulatory audits.
