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Compliance Update - December 2015

2015 has proven to be a challenging and busy year in terms of changes and impacts to all areas in Reverse Mortgages - from origination impacts due, to the Financial Assessment guidelines, to multiple mortgagee letters impacting servicing. All of these changes impact staffing, system development and compliance readiness.  I can’t think of one department within Celink that has not been touched in 2015 with some type of change!

The focus for Compliance this year has been on CFPB readiness and the enhancement of our internal and vendor QC programs.  Although we have always held quarterly scorecards, annual visits and regularly scheduled reviews of adherence and performance for each vendor, we have recently begun our vendor audit program to test the accuracy, SLA’s and compliance of vendors supporting servicing.  Our focus was limited to a select group of vendors for 2015 with a plan to expand to include Tier I and Tier II vendors during 2016.  

Celink has begun the annual review of its written procedures for changes and accuracy.  Completion of that review is expected in the near future.  Although the internal audit team is also reviewing current testing elements, we will wait to finalize our 2016 audit scope and focus until the servicing departments have completed their review.  The 2016 plan will incorporate servicing as well as the mortgagee letter changes to insure that we are in compliance with all regulatory servicing directives.  We are on target to have our audit plan for 2016 completed in December.  

With our purchase of the Quantivate system, our ability to provide enhanced reporting for Vendor and Internal quality control audits will allow for clearer visibility of our compliance efforts and better trend and tracking capabilities.  We are working on building the information needed into the system for the remainder of 2015 with targets to begin full utilization of the product including reporting in 1st quarter 2016.  In addition, the software package will allow for tracking of regulatory changes within state and government agencies and testing our readiness within servicing.  

The compliance department consists of a team of three which handle state licensing and reporting, regulatory compliance and internal and vendor quality control.  Christine Johnson joined the team in early October as our new Quality and Control Manager.  We welcome her to our team.  Her knowledge and experience will be invaluable as we move into 2016 and expand our efforts in the compliance arena.