Saturday, April 5, 2014

Tips, Thoughts and Practices is an email/blog from AcuClix© disseminated to mortgage compliance professionals.

This blog will discuss specific compliance issues, provide examples of non-compliance and tips for managing MLOS.

July 14, 2014

ISSUE: Truth in Lending Regulation Z

This concern keeps compliance officers awake at night. MLOS attempting to differentiate themselves by quoting rates and terms. We have seen many examples of non-compliance in our inspections which can subject the Company to large fines and adverse press. Generally these occur as follows:

1. The MLO describes a scenario but does not include an APR;
2. There is an APR yet there is no date nor limiting language which indicates that the described program is still available;
3. It is an old site (post) that should be removed.

TIP: Some ideas you might use:

1. Require MLO to regularly update sites and information;
2. Disseminate standard limiting language to be added whenever the MLO discusses rates/terms and or loan products;
3. Regularly inspect the social media use to ensure compliance

We hope you find this information useful. Thank you.

Michael J. Wallace, Esq.
Chief Compliance Officer, AcuClix©.