Recent State Audit Request (January 2017) included everything in our program.

We have a client being audited by a Midwest state. The Audit list was exhaustive. The good news is that every single thing on the list is included in Books One, Two, Four, Five, and Six. IF YOU ARE OUR CLIENT.

The regulators requested tons of advertising support and the policies. They asked for copies of Web sites, Facebook, Linked In, Instagram. The regulator asked for proof of customer complaint policies and resolution. (the “Logs”). Can you hear me now?

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Here is where most Brokers and Mini-Cs fall short. The regulator asked for a very exhaustive list of file documents for audit. It could best be described as the initial file plus a final, fully executed and complete closing package. When we provide QC audit services to our clients we look for this. And in over 50% of the files we review, the records are incomplete.

Maybe you should let us audit one or two of your closed loans, before you get a five-part audit request like the one I just referred to.

One final note. Frequent use of the word “Employee”. Not the word “Contractor”. I have beaten this to death with my readers. Employee is a term of art, it means W-2. This regulator asked for all W-2 payroll records and copies of the MLO Agreements and Hiring Procedures. Again, it is all in our program.

What’s on your compliance shelf? If you are not our client, call us today to learn more. (800) 656-4584 extension 103.

Nelson A. Locke, Esq.

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