By now, let’s hope that policy has been decided and is written on QM and loan originator compensation. Success in getting this right will require that those on the front line, and dealing with consumers know this stuff inside and out. They will serve as management’s eyes and ears, so you definitely want to listen to how the new regulations are playing out. This includes any TPO’s that you do business with.
_____ QM/ATR Training Complete and Documented
_____ LO Compensation Training Complete and Documented
_____ Fair Lending Training Complete and Documented
_____ Mock Trials/Testing Set Up to Verify Knowledge
_____ Reference Material in One Location
_____ Help Desk Assistance in Place or Centralized Person to answer questions quickly
_____ Talking points sent out for new regulatory changes
_____ Meetings set up with referral sources to go over changes
_____ Monitoring in effect
_____ Technology person or teams working on Road Map items to keep the momentum going
As you go through these changes remember to not expect perfection and to be open to flexibility and fast changes. Prioritize “quick hits” that will fix problems immediately and save longer term items for after you get through this initial adjustment period.
