Hidden Risk
Michael Celenza
Mortgage Banking Executive, Philanthropist, Free Mason - Helping Banks, Credit Unions, and Lenders improve, using decades of expertise and proven methodology. #Mortgage, #Lending, #Six Sigma, #Technology
As seen on The Chrisman Report 11/10/2016 -
In terms of legal and compliance services for lenders, Michael Celenza with Buckley Advisors writes, "We see potential risk is hiding in plain sight. Segregation of Duties (SOD) has been around for a long time but believe it or not, it's not a regulation, it's a 'Best Practice' and is a primary question found in the Interagency Fair Lending Examination manual. Mortgage Bankers have used this for years but it's less common with Community Banks and Credit Unions in the residential mortgage space, they ask their staff to wear multiple hats, not realizing the potential risk. An example of this is having Loan Officers process and underwrite their own originations. The theory is to properly serve their community, loan officers and their manager must be empowered to make underwriting exceptions to accommodate the customer. Given the increased focus on anti-money laundering (AML), governance, risk and compliance (GRC) and threats of cyber-attack, ransom ware, email scams to fund terrorist organization and mortgage fraud made easier by technology. Taking preventative measures is critical and segregation of duties is a key part of those measures. Buckley Advisors can perform operational analysis, create policies and procedures, and provide guidance in this and many other areas."