For some time I have been concerned about the way certain "cooperatives" seem to be crossing the line in providing compliance support services (via selected, alliance vendors) at the same time that they are providing underwriting, processing, loan products, and various operations functions. Although these cooperatives have (yet) to come under the scrutiny of regulators, I think they one day might, since compliance and underwriting (for example) should not occupy the same space.

I am sure that all the legal bases of their way of doing business have been fully explored and satisfied. And I get that lenders want to go to a cooperative and receive all the services they need, including compliance support. However, in my view, when it comes to compliance there should not be such an ostensibly unorthodox configuration. Indeed, in conversations I have had with regulators, they have pointed out to me that this is a concern of theirs.

Therefore, I have decided to start a new and additional way to serve the compliance needs of the mortgage banking community: the Compliance Collaborative, Inc. (CCI).

The Compliance Collaborative has been in the planning for some time and is already building alliances with well-established vendors that offer compliance - and exclusively compliance! - to residential mortgage lenders and originators.

CCI is now the first and only firm in the country exclusively devoted to mortgage banking compliance that provides a collaboration of the best and finest mortgage compliance providers. And the very first firm to join CCI is Lenders Compliance Group!

Many compliance vendors, consultants, risk management professionals, and law firms are joining CCI in order to provide their respective services to CCI clientele. Any member firm may always be retained separately. But member firms may also be individually retained through CCI or as part of a package of compliance solutions, thereby offering cost-effective and reasonable fees.

In the next few weeks, you will be hearing more about CCI's new website and service plans. We recently issued a Press Release about it and our efforts are being picked up by the media, for instance, here and here and here.