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Update - Renewal Season - HMDA Changes, AIR
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Dear <<First Name>>:
Renewal Season
Remember that we support your license renewal and audit process. If you ever have a problem of any sort, we will work to rebut or repair any finding on our template material. However that doesn't mean that you shouldn't be familiar with the material.
Frequently reported issues
- The materials are too big for a small company. This usually means that you sent everything, not just the piece the regulator requested. We recommend printing only the specific sections requested. It's like when an underwriter asks for a copy of a cancelled check, and you send three months bank statements; it's like saying "here, you figure it out."
- Not knowing what your policy says. If a regulator asks you to explain something, and you say "I have no idea. I just bought these policies." If you don't know the answer, figure it out, or call us. Saying I don't know is a recipe for disaster.
If you feel overmatched by a regulator or investor request call us. We also provide the audit support service.
HMDA Policy Update
We have updated our HMDA compliance and reporting policies and procedures. Remember that this is not a "getting it right" reporting primer, but a policy to ensure that you understand the new requirements as it applies to residential property (not just 1-4 family; mixed use may have to report), the steps that origination staff must take to ensure correct data correction, and reporting distinctions for pre-qualifications vs pre-approvals.
Download HMDA Policy Here
AIR Rules - Minor Response
Make sure you include a system for reporting on serious disciplinary action, such as reporting to a regulator or law enforcement, for violations of policy relating to fraud.
Download Updated AIR Policy here
Change to System for Logging in and Downloading Updates
We had the same passwords for all people who were downloading updates. We are now changing this so that training clients don't have to sort through a bunch of compliances updates, and vice versa. When going to updates and downloads, you will have to register and request access through the system. This takes a few minutes on our side, so be sure to follow up via email if you don't hear within a few hours.
As always, if you have a specific need that you don't see, if you need help with anything or if you just have an idea that will make the system better for everyone, please let me know.
Regards,
Thomas Morgan
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