Special Logs for Client Use

Nelson A. Locke, Esq. Audit, CFPB, Compliance, FHLMC, FNMA, HUD, Uncategorized

To my Clients:

On your compliance shelf you should have at least six manuals at the ready.

Here is the list.

  1. Compliance Book One – Operational Policies and Procedures
  2. Compliance Book Two – MLO Policies and Comp Plans
  3. Compliance Book Three – Reference Material
  4. Advertising Log  LOG Advertising Log Client 011716
  5. Customer Complaint Log LOG Complaint Log Client 011716
  6. QC Manual and Post-Closing Audit Reports LOG Loan Transaction Log Client 011716
  7. Conversation Log for Processors LOG Conversation Log Client 011716

In the event you need items 4 to 7, the links are attached.

Thanks for engaging us, we appreciate it!

Nelson A. Locke, Esq.

(800) 656-4584

 

2 thoughts on “Special Logs for Client Use”

  1. Do MLO’s need to keep a log of all prospective clients that they call?

    *Chae duPont, Esq.*

    *duPont Mortgage, Inc.* 7765 SW 87th Avenue, Suite 102 Miami FL 33173 800.387.6686 305.697.7771 chae@duPontMortgage.com The Key To Your New Home

    On Wed, Jan 20, 2016 at 5:17 PM, Mortgage Industry Compliance Consulting wrote:

    > Nelson A. Locke, Esq. posted: “To my Clients: On your compliance shelf you > should have at least six manuals at the ready. Here is the list. Compliance > Book One – Operational Policies and Procedures Compliance Book Two – MLO > Policies and Comp Plans Compliance Book Three – Referenc” >

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    • Chae, there are two answers to this. The first part – It is a best business practice for a MLO to keep a log of all calls. This can serve to protect you in the event of a future dispute about actual timing of disclosures or if the file was an actual application or not. The second part – The regs, however, don’t require a log, until an application has been taken. Application would be defined as the six items that the CFPB has repeatedly said trigger the word application. A mere 1003, partially completed, is not an application. And once an app exists, the log should be the complete type of log we provided for your use. Finally, remember, adverse actions – many brokers forget these when a loan does not move to an application. My suggestion is that if you pulled credit, you should always log them in and send the adverse action notice to protect yourself and your company.

      Thanks for the good question. Very nice to see you at the Trade Show, the entire staff just said to tell you hi!

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