Through our various audit offerings, Quest Advisors strives to keep you in good standing with investors and regulators, so you can concentrate on your organization’s lending goals. We help clients meet the requirements of federal agencies including branch and servicing audits, concerning residential mortgage loans.
For those lenders using a Mortgage Electronic Registration Systems (MERS), Quest Advisors helps ensure the data input to MERS by the servicer to match what has been documented in the file and security documents.
Quest Advisors also performs advisory and audit services to meet the Bank Secrecy Act-Anti Money Laundering requirements.
- Branch Audits
Quest Advisors provides annual on-site reviews as required by Fannie Mae, Freddie Mac and FHA. The Quest Advisors audit includes reviewing the branch procedures, staff experience levels, signage, overall office organization, security of private data, and the completeness off the loan origination process. Clients are expected to comply with investor/HUD guidelines. Part of the Quest Advisors review includes following both an in-process and denied or withdrawn loan sample through each process of the loan’s progression. In addition to providing management with an evaluation of how the branch is complying with required investor and regulatory requirements, this exercise serves as a learning opportunity and often results in a streamlining of the loan process.
- Servicing Audits
Servicing or loan administration quality control audits satisfy FHA, HUD, Ginnie Mae and Fannie/Freddie Mac requirements and can be scheduled monthly or quarterly depending upon need. These audits review the following, but are not limited to:
- Servicing procedures
- Operations
- Collections
- Loss mitigation
- Cash processing
- Escrow handling/escrow analysis, tax and insurance payments
- Loan file security areas
- MERS Audits & Annual Certification
- Quality Assurance Plan – Lenders and mortgage servicers that utilize MERS are required to establish a quality assurance plan and related processes/procedures to assure the data registered in the system is accurate and that it matches the information as it exists in the lender’s and/or servicer’s internal systems.
- Operational Review – Quest Advisors offers consulting services to assess the lender and/or servicer’s operational processes to identify process gaps that need improvement to meet MERS process requirements. A review is required of MERS procedures to both document the process and the quality assurance plan that is used to validate the accuracy of MERS submitted data to determine if gaps exist and suggest improvement strategies.
- Validation Audits – Quest offers monthly validation audits to ensure:
- The lender is properly conducting monthly system-to-system reconciliations for all the mandatory MERS reporting fields.
- The lender is properly capturing daily errors and reject reports regarding MERS registrations, transfers, and status updates on open-items aging reports; with open items being maintained and tracked on the open-items aging report until resolved.
- Annual Independent Certification – Quest Advisors can also provide the annual independent certification audit that tests the client’s control structure of the system-to-system reconciliation process, the reject/error warning correction process, and adherence to their MERS plan.
- Bank Secrecy Act (BSA)-Anti-Money Laundering (AML) Advisory and Audits
The Financial Crimes Enforcement Network or (FinCEN) now applies the BSA-AML and SAR (Suspicious Activity Report) reporting requirements to independent mortgage lenders and servicers, in addition to traditional regulated depository institutions.
Quest Advisors’ advisory and consulting expertise, conducting reviews of the client’s operational processes, procedures, and controls, determines gaps that need correction or improvement to comply with these requirements. Subsequently, Quest Advisors can help develop required procedures and recommend opportunities for improvement.
Performing periodic audits to test the client’s compliance with the established procedures in advance of the required annual audit allows for changes, which could eliminate costly fines and disruptions in operations.
- CFPB Compliance Management System (CMS) and Independent CFPB Regulatory Compliance Audits
The Consumer Financial Protection Bureau (CFPB) requires all mortgage loan lenders and servicers have a complete Compliance Management System (CMS) in place and have an independent regulatory compliance audit conducted at least annually. Quest Advisors’ advisory and consulting expertise, with considerable emphasis and experience in the regulatory compliance and fair lending area, can help you comply with these requirements. Conducting reviews of the processes, procedures, controls, and communications structure of a client’s CMS identifies gaps that need correction or improvement. Subsequently, if gaps are identified, Quest Advisors can help develop required procedures and recommend opportunities for improvement in the client’s Compliance Management System.
While Quest Advisors can provide the required annual, independent CFPB focused regulatory compliance audit, it may be beneficial to take steps to prepare for the required annual audit. Quest Advisors’ consultants can provide periodic compliance reviews relative to the client’s established CMS procedures and the CFPB federal regulations to identify areas requiring correction and improvement during the year, rather than waiting until the required annual compliance audit.
- Operational Reviews
Quest Advisors’ experienced consultants can conduct in-depth reviews of your lending and/or loan servicing procedures and operations to determine if gaps exist that provide the opportunity for improvement. Such operational reviews include a thorough review of the organizational structure, procedures, actual processes practiced, and loan files compliance with investor and regulatory requirements. Such a review identifies potential shortfalls and gaps in the operation that are opportunities for improved quality and efficiency.
- Compliance Management System Development
Quest Advisors’ consultants can review your existing Compliance Management System (CMS) to determine if any gaps exist, or can help develop a CMS process and procedures for your company if one does not currently exist.
