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Building a robust compliance management system for an evolving mortgage lending regulatory environment

By Heather Clark | Deputy Chief Compliance Officer & Senior Regulatory Counsel, ICE Mortgage Technology
September 20, 2023 · 6 min read

Confidently manage the myriad of mortgage lending regulatory responsibilities by building a robust compliance management system.


For mortgage lenders, constantly changing laws and regulations can make staying current with compliance requirements time-consuming and costly. It takes a collaborative effort to stay on top of it all, and everyone within your organization plays a crucial role. Is your compliance management system empowering your lending organization to navigate the complex regulatory environment? Below are eight components that are essential to building an effective compliance management system, as well as a number of tools that can help lenders manage compliance risk.

Building a robust compliance management system for your lending operation

A compliance management system is the framework by which lenders manage their compliance risks and responsibilities across their organization. An effective system consists of many pieces that need to align and work together to help your lending organization meet all the necessary requirements. Having the below pieces present within your program will put you a step ahead.

Create a risk assessment program

Start by identifying the compliance risks that apply to your business. Then, evaluate any procedures or other controls that manage these risks and the strength of those controls. Where there may be gaps or weaknesses in the ability to control a risk, focus on adding or strengthening controls to manage compliance risks more effectively.

Document policies and procedures

Establish and maintain detailed compliance policies and procedures that clearly communicate compliance requirements and responsibilities to employees for managing compliance risks.

Conduct compliance monitoring and testing

Establish a scope, frequency and schedule for monitoring and testing based on your risk assessment results. If corrective action plans become necessary, measure and evaluate the results to ensure you’re seeing the necessary improvements.

Establish regular reporting and communication

Set expectations for reporting requirements and a communications plan for when compliance updates will be shared with employees, senior management and the board. It is also important to establish a communications protocol that will escalate any regulatory compliance issues and share critical messaging.

Host compliance training

Build and maintain compliance training programs based on role, line of business, conduct and more.

Leverage compliance technology

Technology is invaluable to helping lenders manage compliance risk. When evaluating a solution, first define your business requirements and look for platforms that can help you use automation wherever possible.

Coordinate with regulators

Set a protocol for how to engage with regulators, including building standard processes to receive and respond to inquiries, track examination findings and identify stakeholders to engage during regulatory discussions.

Maintain oversight

Establish clear roles and responsibilities when it comes to compliance and maintain governance through the board and senior management.

Proven origination solutions to support your compliance management system

As laws, rules and regulations increase in complexity, the processes and systems mortgage lenders rely upon to manage them also need to evolve. At ICE, we’re dedicated to helping our customers leverage the tools and automation necessary to meet their compliance needs. With decades of expertise and service to lenders, our solutions are designed to improve loan quality across the entire lending workflow. We employ and regularly consult with compliance, legal and industry experts to build automated compliance solutions that make it easier for our customers to keep up with the evolving regulatory environment. Our comprehensive suite of industry leading built-in compliance solutions include: 

Encompass® and Encompass Compliance Service™

Encompass, the industry’s most complete end-to-end mortgage lending platform, does the heavy lifting to enable you to build and maintain a complaint workflow. With hundreds of state and federal laws and regulations, our Encompass Compliance Service , allows you to feel confident that you’re identifying and meeting the necessary requirements. Plus, you’ll be able to immediately make changes to improve loan quality and reduce the risk of mortgage buybacks by running automated compliance checks for regulations such as KBYO, ATR/QM, HOEPA, HMDA, TILA, NMLS licensing and more.

Encompass Docs Solutions™

Available within Encompass, our Document Solutions offer a single source to find state and federal mortgage documents within your LOS, so you have access to quality, compliant documents for every loan.

AllRegs®

Our AllRegs platform allows you to access the most accurate, comprehensive and up-to-date compliance and regulatory information to deliver better quality loans and avoid errors that cost you both time and money. The AllRegs platform is also accessible through Encompass.

Beyond our technology solutions, we also offer policy templates and training courses to our customers - a great place to start is our Mortgage compliance for origination course. 

Preparing for what’s on the horizon for mortgage compliance

Now is a great time to evaluate the compliance capabilities within your LOS and what your technology partner has planned for the future. To stay ahead of today’s ever-changing regulatory landscape, your LOS provider should be constantly evaluating upcoming changes and helping you prepare for and make any necessary adjustments without disruption to your business. I also encourage you to examine any built-in compliance capabilities within your LOS because these can do more than just help you reduce risk. They also save you time and money. According to a recent MarketWise study, lenders who leverage automated compliance testing within their workflow save an average of 20 minutes and $14 per loan. What impact could this have for your business? Learn more about how Encompass can help you confidently meet compliance requirements and make a return on your investment for many loans to come.

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