Brokers who rely on their lender’s captive LOS system may be missing proof of disclosure and subject to adverse findings in an audit.

That pretty much says it all.

During April Audits we saw quite a few instances of Brokers relying on Lender disclosures.

These Brokers opted to quit using Point similar systems to save money.

When audited, their files were missing LEs or CDs and the Regulators cited the Broker for lack of attention to his/her client and the rules.

Brokers need to remember, the rules say that either the Broker or the Lender can prepare disclosures.

However, the Broker must be sure the client got them and the Broker must be sure the Broker has a copy for their post closing archives, in case of audit.

Do you?

Thanks,

Nelson A. Locke, Esq.

Compliance Services, USA.

(800) 656-4584

nl@lockelaw.us

 

 

 

 

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