| Frequently Asked Questions - Mortgage Compliance | June 20, 2013
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Greetings!
So many questions, so few answers!
Sometimes the question is all you'll get to hold on to!
And when you do get an answer, occasionally you are more confused than before you even asked the question in the first place.
Or, you take your just begotten answer to somebody whom you think may have even more of an answer, only to find out that your answers conflict with each other!
And what about those murky grey areas of regulatory compliance, where questions abound, thriving in a no-man's land of uncertainty. Suppose you get an answer to one of those questions?
Would you try to navigate the high seas of uncertainty with an answer that came from a question that lurked in those fathomless grey areas of the deep?
Will you be that special someone who takes the leap into the void and risks becoming a regulator's test case?
Here's how we're going to help!
We have decided to provide a Frequently Asked Questions website and blogspot, where you can go to pose those inscrutable questions that beg for answers!
But more about that in a minute.
First, I want us to have a frank talk about mortgage compliance questions and answers. So please read on and let's get real!
Courage,
Jonathan
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Announcement
|  Jonathan Foxx
President and
Managing Director
Lenders
Compliance
Group 
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Haven't a Clue? | |
We are an industry of questions and answers. A highly regulated industry of questions and answers.
Regulatory guidelines and compliance implementation are a never-ending assault on our time and resources. Most of us are very devoted to providing the consumer with a safe and sound loan origination experience, rarely trying to push the compliance envelope, and surely striving to comply with federal and state law as well as loan product requirements.
Here's a clue: there is no omniscient Answer Man or Answer Woman. Sorry!
There often is not a one-size-fits-all answer to a regulatory question.
The plain reading of a regulatory statute does not always derive compliance solutions. The courts are filled with disputes regarding the interpretation of text within the "four corners" of the document.
And sometimes the courts hold differing rulings, even contradicting one another.
It reminds me of the comedian Jackie Mason's line, when pondering a question: "On the one hand, this is the case; but on the other hand, that is the case; then again, on the one hand this also is the case; however, on the other hand, that is the case, too." |
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Mistakes were made! | |
Usually, nobody wants to say to a regulator, "well, mistakes were made!" Not a good idea!
I have said, and will continue to say, preparation is protection with respect to mortgage compliance.
Mistakes are unavoidable, but they can be reduced.
The job of mortgage risk management is to identify, mitigate, reduce, and, if fortune shines upon us, eliminate risk! Overcoming inertia is front and center to managing compliance, no matter what you may claim to be your own tolerance to risk.
To quote another famous Jackie Mason quip: "We were going to do it before the hurricane, but decided to wait."
Compliance must be proactive, or it is not compliance. Perhaps it is something else, but it is certainly not compliance. Trust me, there really is such a thing as being too late! |
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The FAQs and nothing but the FAQs | |
With the foregoing in mind, our firm has decided to offer our own FAQs every week, supported by our own Subject Matter Experts.
I can't say we'll post each answer on any specific day, or a certain time of day. But you'll get them!
Drawing on compliance topics that we are faced with contemplating continually on behalf of our clients, you will receive our FAQs.
And we'll build a Library of FAQs for you to visit whenever you want!
A Frequently Asked Question and its Answer - weekly, one at a time. Questioners' names will not be published. We want only solid questions from companies, not consumers!
Our goal is to enhance comprehension by offering a helpful answer.
And the good part? You finally get to ask the lingering question that just won't go away!
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Let's Collaborate! | |
So let's collaborate on questions and answers.
You take the former, and we'll take the latter.
Sometimes, we may answer with a question for a question!
Sometimes, we'll need to let you know that the question is great, but it does not have an answer currently supported by regulatory guidelines, verdicts, banking law, proposed or final rules!
Whatever the case, maybe, just maybe, we'll learn something new together!
We will begin the weekly FAQs for mortgage compliance next week and send you online access, so that you can pose your questions.
And, of course, I will announce the activation in a forthcoming Announcement!
In the meantime, think of a great question to ask us! |
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LENDERS COMPLIANCE GROUP is the first full-service, mortgage risk management firm in the United States specializing exclusively in outsourced mortgage compliance and offering a full suite of services in residential mortgage banking for banks and non-banks. We are pioneers in outsourcing solutions for residential mortgage compliance. We offer our clients real-world, practical solutions to mortgage compliance issues, with an emphasis focused on operational assessment and improvement, benchmarking methodologies, Best Practices, regulatory compliance, and mortgage risk management.
This newsletter is free to subscribers, clients, and colleagues, who also regularly receive our free Mortgage Compliance Updates, Announcements and Commentaries.
Information contained in this email is not intended to be and is not a source of legal advice. The views expressed are those of the contributing author, as well as news services and websites linked hereto, and do not necessarily reflect the views or policies of Lenders Compliance Group, any governmental agency, business entity, organization, or institution. Lenders Compliance Group makes no representations concerning and does not guarantee the source, originality, accuracy, completeness, or reliability of any statement, information, data, finding, interpretation, advice, opinion, or view presented herein.
� 2013 Lenders Compliance Group, Inc. All Rights Reserved. |
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