This past week I was contacted by several clients who received Audit Letters in the mail. One of them sent me a copy of the Audit Letter to review.
The Audit Letters are ominous because they are more robust than I have seen in the past and indicate the State is aggressively incorporating federal guidelines. It’s not just about state regulations anymore.
I think it would be a good idea for you to think about the below, and email me with questions. Some of these things might apply to you.
Here are some examples of just a few of the items included in the eleven page Audit Letter.
- Emphasis on MLO Employment Contracts and Employee Files, likely to investigate compliance with training and to analyze your W-2 versus 1099 situations
- List of third party providers to investigate Privacy Act Compliance, possible unreported ABA situations, and payments between entities
- Form 941 – Federal Employer Quarterly Tax Return (I told you so)
- Warehouse Line Agreements – looking for more than one agreement and comparing financials used for line approval with actual books and records
- Advertising Log with samples back two years
- Proof of Acceptance of Duties of Managers and Officers
- Bank Accounts verifying third party payments and CFPB Comp Plan commission compliance
- Corporate Minutes or LLC Records to establish Compliance as ongoing topic of Management
- Random spot checks of minimum net worth requirement at any point in time to detected unreported deficiencies in net worth
I have the actual audit letter should anyone want to discuss it.
Call us at (800) 656-4584.