Education & Events
CBC I: The Mortgage Origination Compliance Process - Beginning to Audit & Back Again
In fall 2018, we solicited suggestions regarding areas in which compliance officers were struggling, and got many responses. While a variety of subjects were offered, managing the compliance process was a recurring theme. We have chosen to present this material within the context of mortgage loans.
Based on 2017 HMDA Data, traditional financial institutions originate less than 50% of the mortgages made in the United States. This, combined with general market pressures, has often resulted in management either creating incentives for lenders, or considering other approaches to increase market penetration. However, even if your bank is not implementing or considering these approaches, the concepts presented will be useful to you.
We will begin with the underlying requirements for incentivized mortgage programs, based in part on the new “Loan Originator Rule: Small Entity Compliance Guide” that was released by the Bureau of Consumer Financial Protection in November 2018. We will go beyond just the recitation of the rules and regulations. We will review how to create a mortgage compliance management program and detail the impacts it can have on your bank, whether you have an incentive program or not.
All compliance issues begin with risk assessment – then using the risk assessment as the basis for managing the entire process – policy, procedure, the compliance officer role in the process, compliance monitoring within the lending function, and finally audit schedules, whether audit is external or
internal. Of course, audit results impact your risk assessment, so the compliance “circle” is ongoing. Only with all these features can an institution have a fully integrated mortgage compliance program.
- Subjects as released by the CFPB and other federal agencies.
The Mortgage Origination Compliance Process
- Loan Originator Incentive rules
- Impact on the mortgage process
- Building the Compliance “Circle” for mortgage loans
- Risk assessment
- The Compliance Officer Role
- Compliance Monitoring
- Circle back to Risk Assessment
After promising Regulation CC changes, the CFPB has initiated a new comment period, so any changes will be some time in the future. They also appear to be taking their time with many other changes that were mandated by recent changes in the law. Therefore, we expect no major regulatory issues, at least in the near term. Other subjects for future seminars will be shaped by regulatory events as they unfold. The CBC quarterly compliance program remains committed to providing as much up to the minute information as possible. The program will closely monitor releases from the CFPB and other agencies to assure that you have the most up to date and accurate information possible.
Bill Elliott, CRCM, Senior Consultant and Manager of Compliance
Bill Elliott has over 40 years of banking experience. As a compliance consultant and manager of the compliance division with Young & Associates, Inc., Bill works on a variety of compliance-related issues, including leading compliance seminars, conducting compliance reviews for all areas of compliance, conducting in-house training, and writing compliance articles and training materials. During his career, Bill spent 15 years as a compliance officer and CRA officer in a large community bank, and also worked for a large regional bank. He has been a lender for consumer, commercial, and mortgage loans, and has managed a variety of bank departments, including loan review, consumer/commercial loan processing, mortgage loan processing, loan administration, credit administration, collections, and commercial loan workout.
8:30 a.m. Registration & Continental Breakfast
9:00 a.m. Program Begins
12:00 p.m. Lunch (included)
1:00 p.m. Program Resumes
4:00 p.m. Program Adjourns
IBA Center for Professional Development
8425 Woodfield Crossing Blvd Suite 155E
Indianapolis, IN 46240-7321
$350 IBA Member
$180 Each Additional IBA Member
100% Surcharge is applied for Non-Members.
WHO SHOULD ATTEND
Compliance Officers and Auditors should attend this session. In addition, all personnel with responsibilities for managing the mortgage process at all levels, including senior management and others should also consider joining us for this session.
Elizabeth DeHaven, Education Coordinator
You will receive an e-mail confirmation at
Within three or more business days prior to the day of an educational program, no cancellation charge will be assessed. Within two days prior, 50% of the fee is assessed. Refunds are not provided for cancellations the day before or absences on the day of the program. Substitutions are welcome at