Arizona Central Mortgage Quality Control & Compliance Policy
Steven P Bernstein dba Arizona Central Mortgage along with all its employees and contractors will abide by all policies, procedures, guidelines and statutes required to originate, process, underwrite and close residential 1-4 family home loans, by the United States government, the Arizona State government, the CFPB, The Federal Reserve, the FTC and all other governing bodies. Steven P Bernstein dba Arizona Central Mortgage will evaluate and update quality control policies and procedures on a ongoing basis, based on guidance from the Consumer Financial Protection Bureau,
1 Licensing & Continuing Education: All company employees and subcontractors will meet or exceed all Federal, State, and Investor licensing and continuing education requirements.
2 Bookkeeping All company employees and subcontractors will meet or exceed all bookkeeping guidelines including those required by the Financial Accounting Standards Board, (FASB) and the Arizona Department of Financial Institutions, AZDFI.
3 Record Retention All company employees and subcontractors will meet or exceed all record retention guidelines including Loan Logs, General Ledgers, Advertising Materials and Financial Reports for no less than 5 years.
4 Marketing & Advertising All company employees and subcontractors will abide by truth in advertising REG-Z requirements providing full disclosure of mortgage rates and terms including the APR and the terms and fees used in its calculation. Moreover, the company will abide by, and be extremely sensitive to Fair Housing, Equal Credit and Civil Rights laws.
5 Loan Origination All company employees and subcontractors will abide by industry accepted rules, regulations, guidelines and laws for originating and processing residential home loans, including quality control reviews regarding taking loan applications and verifying the accuracy and completeness of the data provided. Only licensed MLO’s will be permitted to take applications and quote interest rates. All applications will be processed and decisioned in a productive and timely manner, using checklists to verify all applicant’s identification, income, assets, credit, debt, property value, clear title, required insurance and appropriate, timely and full disclosures. Compensation will be earned and distributed based on negotiated signed compensation disbursement agreements between Steven P Bernstein dba Arizona Central Mortgage, its borrowers and wholesale lenders.
6 Employee Records All company employee records will be maintained for a minimum of 2 years after employment ceases to exist. This includes a minimum of employment application, employment agreement, W4 verifications, two forms of accepted identification, acceptable credit report, 2 years written and/or verbal prior employment verification and all other documents and verification procedures required by law, the NMLS and AZDFI.
7 Disposition of Funds Any funds received by Steven P Bernstein dba Arizona Central Mortgage from the borrower will be immediately deposited into a borrower’s trust account and will not be commingled with any other personal or business accounts. All 3rd party fees will be maid out directly to the service provider, or will be collected through title company i.e., (Credit Report Fees, Appraisal Fees, Inspection Fees, Termite Report Fees, Title Report Fees, et al).
8 Appraisals All appraisals are the property of the borrower and will be provided to the borrower within 72 hours of receipt.
9 Safe Desk Policy All company employees will maintain a clean desk policy, locking computer screens and desks when away from said desk. All borrower documents must be filed and locked when away from desk in order to maintain appropriate privacy and security.
10 File Backup Steven P Bernstein dba Arizona Central Mortgage will maintain written and/or computer files for a minimum of 5 years. All files maintained via computer will be backed up on a secondary source which may include a separate paper file, a secondary computer, or a secured online storage repository.
11 Origination & Processing All company employees and contractors will meet or exceed Federal, State, and Investor licensing and continuing education requirements, and will be compensated based on IRS, State of Arizona and CFPB rules, regulations,guidelines and statutes. All borrowers will receive required disclosures from initial loan application, to file processing to file disposition. Each loan will be decisioned upon the receipt of the 6 required application data points, aka ALIENS: 1. Address, Loan Amount, Income, Employment, Name and Social Security Number. Each application will be decisioned within 30 days of application and if preliminarily approved, will receive a Prequalification Letter along with a weekly Loan Status Update, LSU. Each borrower will receive an adverse action letter, aka denial letter within 60 days if loan is withdrawn, counter offer is not accepted, or application is denied.
12 Post Close Steven P Bernstein dba Arizona Central Mortgage will review each file using a post close checklist that includes checking for required mortgage disclosures, signatures, dates, supporting documents and disposition of funds.
13 Statutes & Guidelines All company employees and contractors will abide by all Federal, State and Investor guidelines and statutes including but not limited to those listed below. Copies of the following statutes will be provided upon request:
A. STATE OF ARIZONA
D. SAFE ACT
H. PATRIOT ACT
I. DO NOT CALL REGISTRY
J. CIVIL RIGHT ACT
K. FAIR HOUSING
V. INVESTOR GUIDELINES