Confidentiality – a word of advice to you owners, officers, and directors.

When you communicate with your entity’s attorney, if the communication has to do with legal action or regulator issues – do all you can to protect the confidentiality of the conversation the two of you are having.

If you “cc” an MLO, a processor, or for that matter any other third party other than an attorney, you may unwittingly place confidentiality at risk. You may find that emails which you intended to be private – become the subject of discovery.

All too often I see compromising situations where in the event of litigation or regulator action – your attorney client privilege might be vulnerable.

That’s it for now.

Compliance Services USA

(800) 656-4584


Audit Notices are FLYING OUT


Yes it is true. Here we are about 10 days into the new year. As of yesterday, six clients in Florida, Texas, and North Carolina had received audit notices. That’s about 3% of our client base meaning that we could see a very high audit rate this year – perhaps as high as 30%. The agencies are getting really aggressive.

All of the audit notices were accompanied with a checklist that incorporated the items on our CFPB Audit Preparation Checklist which is page four of compliance book three. If you don’t know what that is, email us at we will send you a copy. We have been telling you since 2015 that the audit notice process is standardizing, so it is easier for you to be able to know in advance what a regulator is looking for.

The CFPB Audit Checklist is the best roadmap you could have. Have you ever read it? Book Three page four. Or email us.

Here’s to a Happy New Year! Thanks for engaging us as your Compliance Expert.


Nelson A. Locke, Esq

Jon Gordon, Director

Compliance Services, USA

(800) 656-4584