Monday, August 19, 2019

Why do I need an 800 Number? New York State Whistleblowers

This update addresses some of the issues we discovered in the past 30 days.

Privacy policies and marketing - The reason you MUST have a toll free company number

An 800 number provides customers with a direct, toll-free line to communicate with company representatives. The Gramm-Leach-Bliley (GLB) Act states that customers must have an opportunity to do what is called "opting out" of information sharing. Customers have the absolute right to call and direct that their personal information not be shared with non-affiliated third parties. Having an 800 number fulfills the requirements of the GLB Act.

Further, we recommend using the Privacy Policy from your LOS to populate your website or marketing policy, so you provide the same information across all platforms.

Download Link

Whistleblower Policy - Reporting responsibilities and protection of those reporting

Employees should maintain high standards of business and personal ethics in their conduct within the workplace. New York State, among others, requires lenders and brokers to have a Whistleblower Policy in place. Acting ethically in a workplace includes reporting any concerning or suspicious activity as soon as possible and in a professional manner. The Whistleblower Policy encourages directors, volunteers and employees to report suspicious activity, as well as protects those who report activity from any retaliation or adverse employment consequences.

View Sample Policy Here

Vet exhibits and organize your loan files efficiently!!

Prior to forwarding files to an underwriter or investor, ensure you properly organize and vet the contents. Using a checklist will help you do this efficiently. However, until you send them, do they sit on your computer as a mish-mash jumble of files? While many LOS systems will index exhibits for you, having access to the specific document before and after you upload it can help with further processing and post-closing document review.

This policy provides guidance on proper loan file taxonomy of exhibits which will help with post-closing delivery, audits, submitting exhibits to insuring and guarantee, and state regulatory reviews.

In addition, proper file naming conventions can help organize many individual exhibits into one single file.

View Sample Electronic Document Stacking Policy

Some CE Training May Meet Non-NMLS Compliance Training Requirements

Your Loan Officer's continuing education (CE) program may cover some of the compliance training requirements. We offer a compendium of compliance training recommendations on our affiliate site - With several of our affiliates, you can request add-on certificates to meet required non-NMLS compliance training, such as Anti-Money Laundering, Fraud, and TILA-RESPA. This can save your loan originators time and money.

Unfortunately, the CE training can't cover every element of your compliance training and for those we provide those to you here:

Did you know that we can also verify whether your licensing or other training does meet some of the regulatory requirements? All we need is a copy of the syllabus and training course materials, such as text, quiz or powerpoint.