Mortgage Loan Origination Compliance Checklist
This comprehensive mortgage loan origination compliance checklist ensures regulatory compliance with CFPB, HUD, FFIEC, FRB, OCC. Loan origination compliance review for mortgage lenders covering TRID disclosure timing, HMDA data collection, fair lending, RESPA servicing, and CFPB ATR/QM requirements per Dodd-Frank, RESPA, TILA, ECOA, and FHA/VA program requirements. Mortgage compliance violations result in significant CFPB enforcement actions and class action exposure. Complete all sections to ma
- Industry: Financial Services & Banking
- Frequency: Monthly / Quarterly
- Estimated Time: 45 minutes
- Role: Compliance Officer / Branch Manager
- Total Items: 18
- Compliance: CFPB, HUD, FFIEC, FRB, OCC
TRID Disclosure Timing and Content
Verify TRID compliance per CFPB TILA-RESPA Integrated Disclosure rule.
- Is Loan Estimate delivered within 3 business days of application receipt per 12 CFR 1026.19(e)?
- Do Loan Estimate charges fall within applicable tolerance limits at Closing Disclosure comparison?
- Is Closing Disclosure received by borrower at least 3 business days before consummation per 12 CFR 1026.19(f)?
- Are changed circumstances documented to support any fee increases above original Loan Estimate?
- Is Ability-to-Repay (ATR) analysis documented per CFPB 12 CFR 1026.43(c) for all covered transactions?
Fair Lending and ECOA Compliance
Verify fair lending compliance per ECOA and HMDA.
- Are HMDA demographic data fields (race, sex, ethnicity, age) collected at pre-application per 12 CFR 1003.4?
- Are written denial notices sent within 30 days with specific adverse action reasons per ECOA 12 CFR 1002.9?
- Is comparative file review or regression analysis conducted to detect unexplained pricing disparities by race or sex?
- Does bank's CRA performance show adequate lending in low-to-moderate income areas per CRA assessment area?
- Has geographic loan distribution been reviewed for potential redlining patterns?
RESPA and Servicing Compliance
Verify RESPA compliance per HUD RESPA Rule.
- Are all settlement service referrals free of undisclosed kickbacks or fee-sharing per RESPA Section 8?
- Are escrow account calculations within RESPA maximum escrow limit of 2 months cushion?
- Are annual escrow analyses conducted and statements sent per RESPA 12 CFR 1024.17?
- Are borrower Qualified Written Requests (QWR) acknowledged within 5 business days and responded within 30 days?
Licensing and Registration
Verify NMLS licensing currency.
- Are all loan originators NMLS-licensed in required states with current annual renewal?
- Have all MLOs completed 8 hours annual NMLS continuing education including state-specific requirements?
- Have required background checks been conducted on all new MLOs per SAFE Act requirements?
- Do all loan documents identify the licensed entity and individual MLO with NMLS unique identifier?
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Why Use This Mortgage Loan Origination Compliance Checklist?
This mortgage loan origination compliance checklist helps financial services & banking teams maintain compliance and operational excellence. Designed for compliance officer / branch manager professionals, this checklist covers 18 critical inspection points across 4 sections. Recommended frequency: monthly / quarterly.
Ensures compliance with CFPB, HUD, FFIEC, FRB, OCC, HMDA, ECOA. Regulatory-aligned for audit readiness and inspection documentation.
Frequently Asked Questions
What does the Mortgage Loan Origination Compliance Checklist cover?
This checklist covers 18 inspection items across 4 sections: TRID Disclosure Timing and Content, Fair Lending and ECOA Compliance, RESPA and Servicing Compliance, Licensing and Registration. It is designed for financial services & banking operations and compliance.
How often should this checklist be completed?
This checklist should be completed monthly / quarterly. Each completion takes approximately 45 minutes.
Who should use this Mortgage Loan Origination Compliance Checklist?
This checklist is designed for Compliance Officer / Branch Manager professionals in the financial services & banking industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.
Can I download this checklist as a PDF?
Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.