Big Picture
Mortgage compliance regulations such as TILA, RESPA, ECOA, Fair Housing Act, HMDA, SAFE Act, and many other regulations set the framework in which a financial institution must build their compliance program. Regulators regularly test and expect financial institutions to comply with these regulations to provide transparency, fair lending, and protection to consumers getting a mortgage.
Client Scenario
An early-stage fintech preparing for entry into the mortgage market needed compliance and CMS support. The fintech, aiming to leverage artificial intelligence throughout the mortgage origination process, did not have the internal expertise to develop effective CMS and Financial Crimes programs.
Asurity Solution
Asurity Advisors engaged mortgage, compliance, and BSA/AML/OFAC experts to engage with the client. Asurity’s experts performed a deep dive into the client’s business plan, proposed product offerings, and origination processes. Throughout the discovery phase, Asurity met with the client to understand their vision for using AI in the mortgage process and advised on compliance implications and requirements that must be considered. In building its mortgage origination process, Asurity provided NMLS state licensing advisory support. Additionally, Asurity helped the client build the governance infrastructure of their CMS and Financial Crimes Compliance programs. Asurity wrote and delivered over 50 policies covering regulatory requirements, CMS pillars (e.g., complaint management, issue management and corrective action, change management, etc.), financial crimes compliance requirements, and secondary market quality control/quality assurance requirements. Upon conclusion of the building phase, Asurity Advisors continued to provide support in a seconded capacity.