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Mortgage Origination – CFPB

The CFPB Mortgage Origination Examination Procedures cover all aspects of the mortgage origination process and are applied to both mortgage brokers and lenders.

The following modules are the active areas of controls, which will be assessed and reported on during a CFPB assessment:

Module 1 – Company Business Model

  • Internal structure, controls, and compliance management
    • Independence and reporting structure
    • Applicable law
    • Appropriateness
    • Timeliness
    • Corrective and preventative action

Module 2 – Advertising and Marketing

  • TILA/Regulation Z
  • RESPA/Regulation X
  • ECOA/Regulation B
  • SAFE Act
  • FCRA/Regulation V
  • Mortgage Acts and Practices/Regulation N
  • Other related risks to consumers (UDAAP)

Module 3 – Loan Originators

  • Regulation Z
  • Prohibited Payments to Loan Originators
  • TILA
  • Prohibition on Dual Compensation
  • Prohibition on Steering
  • Loan Originator Qualifications and Documentation
  • SAFE Act

Module 4 – Loan Disclosures and Terms – Closed-End Residential Mortgage Loans

  • Loan Estimate/Regulation Z

Module 5 – Loan Disclosures and Terms – Other Residential Mortgage Loans

  • Regulation Z
  • Regulation X
  • Homeowners Protection Act
  • Other related risks to consumers (UDAAP)

Module 6 – Appraisals

  • Regulation Z
  • Regulation B
  • Other related risks to consumers (UDAAP)

Module 7 – Underwriting

  • Regulation Z

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