In the November 22, 2016, Federal Register (81 FR 83811) the Consumer Financial Protection Bureau (CFPB) published the Fall 2016 edition of its Supervisory Highlights, click here, which reports CFPB examination findings assessing compliance with Federal consumer financial laws in the areas of automobile loan origination and servicing, debt collection, mortgage origination and servicing, student loan servicing, and fair lending for the May 2016 through August 2016 report period. This memorandum will focus on the examination findings for mortgage origination. CMS Deficiencies: The overall mortgage origination compliance management system (CMS) at one or more institutions was weak because it allowed violations of Regulations G (12 CFR Part 1007 – Federal Registration of Residential Mortgage Loan Originators), N (12 CFR Part 1014 – Advertising), X, and Z to occur. For example, one or more institutions did not conduct compliance audits of mortgage origination activities, had weak oversight of service providers, and had not implemented procedures for establishing clear expectations to adequately mitigate the risk of harm arising from third-party relationships.
