Department and Function Reviews – NMP Skip to main content

Department and Function Reviews

Sep 16, 2016

Question: What department and/or functions are subject to review from regulators or investors?

Answer
As the world of mortgage compliance continues to evolve and grow, virtually every department/function is subject to review.

More specifically, Fannie’s Mortgage Origination Risk Assessment guide outlines areas that are subject to review, which include:

►Organizational Structure and Governance
►Origination Channels – Retail (as applicable) and Correspondent (as applicable)
►Underwriting and Approval
►Closing/Post-Closing/Funding
►Pre-Funding and Post-Closing Quality Control
►Compliance/Internal Audit
►Secondary Marketing
►Technology
►Business Continuity and Disaster Recovery 

While Quality Control, as it relates to timely and proper execution of documents, seems to gather much of the attention in the press, it has become increasingly important to ensure that all of the departments/functions noted above are prepared to answer the bell when your investor or regulator comes knocking.

It is critical to not only have your policies and procedures in place but also that you have demonstrated you are acting in accordance with your policies and procedures.

In addition, you should be prepared to provide evidence that your senior management team and/or Board of Directors has approved the policies and procedures that provide the blueprint for your mortgage banking functions.

From a Risk Management and Secondary Marketing perspective it is important to identify, monitor and adhere to specific risk tolerance metrics that are used to manage the interest rate risk associated with your pipeline. An internal audit and/or review by an independent third party can help you identify your areas of strength and weakness.



Dan Duggan is director of Secondary & Capital Markets for Lenders Compliance Group.

About the author
Published
Sep 16, 2016
States Tighten Mortgage Rules For Home Equity Investments

Massachusetts, Maine, and Illinois are expanding oversight of home equity financing

West Capital LO Challenges Contractor Status, Required Fees

A former originator alleges unpaid overtime, recurring tech charges, and company restrictions that he says undermine his independent-contractor status

CFPB Closes 40% Of Investigations, Keeps Mortgage Enforcement In Focus

The federal watchdog closed thousands of supervisory and investigative matters as it narrowed oversight

Midterms Loom With Mortgage Policy Changes Already In Motion

As voters head to the polls Tuesday, Washington is weighing changes to refinancing costs, loan pricing, and lending regulations

UAD 3.6 Deadline Is Monday. Are Brokers Ready?

Wholesale lenders have adopted different rules for appraisal transfers, loan product changes, and reporting formats, adding complications for brokers and appraisers ahead of the Nov. 2 mandate

Friday Harbor Expands AI Appraisal Reviews As UAD 3.6 Deadline Nears

The new capability adds more than 350 automated checks as lenders prepare for the November 2 mandate

Oct 27, 2026