Community Bankers for Compliance Program
Spring Live Regulatory Seminar
Date: April 9 & 10, 2019
Ramkota Hotel & Conference Center, 800 S 3rd St Bismarck ND
Day 1: The Mortgage Origination Compliance Process Beginning to Audit and Back Again
In Fall 2018, we solicited suggestions regarding areas in which compliance officers were struggling. We received 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. But 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. But 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.
Who Should Attend
Compliance Officers and Auditors should attend this session of the first quarter CBC Program. 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.
The Mortgage Origination Compliance Process – Beginning to Audit and Back Again
- 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
Day 2: RESPA - Regulation X The Role of a Compliance Council
The afternoon session of the CBC seminar will focus on the role of the compliance council in the life of your bank. We will also covering the requirements of Regulation X: RESPA. While there have been no major changes in the regulation, the application of the servicing portion of the regulation has been altered with the concept of Successor in Interest. We will cover the regulation in full, with the presentation focused on those areas which will be most useful for the
attendees. Some portions of the servicing rules will not apply to everyone, and those sections will be truncated. We will not be covering the Good Faith Estimate and HUD-1 sections of the regulation, as they have limited to no use for attendees.
RESPA covers many topics, including mortgage origination, kickbacks and unearned fees, and servicing. In recent months, we have received hotline questions in all areas of the regulation, but most concerning is in the area of Section 8 of the underlying law (kickbacks and unearned fees). As banks struggle with market share, more and more management is trying to find ways to improve their position in the marketplace. Many, but not all, approaches are legal. We will include a section discussing real-life hot line calls and marketing approaches where
we have been asked for help, taking care not to include any information regarding the CBC member who submitted the question.
The day will end with the concepts and requirements of escrow, as we know that all banks do not offer that service to their customers. This will allow non-escrow banks to head home early without missing important sections of the presentation.
Who Should Attend
Compliance Officers and Auditors should attend this session. In addition, all personnel with responsibilities for managing the compliance process, including senior management and others should also consider joining us for this session.
The Role of the Compliance Council
- How to set up and utilize a compliance council
- The compliance officer’s role in this process
- Who should be members of the council
- How to determine the agenda and omit from the agenda
- How often to meet
- Using the council minutes to provide periodic updates for the Board of Directors
RESPA - Regulation X
- RESPA Introductory Items
- RESPA General Issues
- Disclosures at Application
- RESPA Mortgage Servicing Rules
ICBND and Community Bankers for Compliance (CBC) Members: If 2019 annual dues of $1,500 for one attendee or $1,800 for two attendees has been paid, no additional cost for this session.
$200 per 2-day session for each additional attendee above 2 attendees.
ICBND Members who are not members of the CBC Program $950 per 2-day session for the first attendee.
$600 per 2-day session for each additional person.
$1,400 per 2-day session for the first attendee.
$1,000 per 2-day session for each additional attendee.
Registration on Day 1 of each 2-day seminar will be at 9:30AM and the session will run from 10:00 AM-4:30 PM. Day 2 will run from 8:30 AM-3:00 PM.
15 days or more prior to seminar date, you will receive a full refund of the registration fee; 8-14 days prior to seminar date, you will receive a 50% refund; and 0-7 days prior to seminar date, there will be no refund given.