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Welcome to the RC Certify Portal

   
PROGRAM
Overview
In 2007, the Conference of State Bank Supervisors (CSBS) and the American Association of Residential Mortgage Regulators (AARMR) began a comprehensive initiative to bring greater uniformity, modernization and effectiveness to the mortgage examination process. CSBS and AARMR established the Nationwide Cooperative Agreement for Mortgage Supervision (NCA), which was signed by all the states, as well as the District of Columbia and Puerto Rico. The NCA enables states to share information and coordinate their efforts as they supervise lenders. CSBS and AARMR are establishing national examination guidelines for state regulators and the examination guidelines call for the use of technology to automate the repeatable parts of mortgage examinations and help examiners move from a sample-based audit to a process in which examiners can look at 100% of an originator’s production.

To accomplish the goals behind the guidelines, state regulators knew that they would need some sort of system that could efficiently gather the necessary loan information in an electronic form and quickly audit it against all applicable laws and regulations. After considering building such a tool internally, delegates from CSBS and AARMR set out to source available technology that had already been developed in the mortgage industry to automatically audit loans for compliance. In April 2008, following an eight-month evaluation process, CSBS and AARMR selected ComplianceEase® as the technology provider.

Multi-State Exams
Multi-state examinations fall under the NCA and are selected and directed by the Multi-State Mortgage Committee (MMC) representing all states. With the MMC’s adoption of a technology-based examination process, the examination team can utilize a suite of applications throughout various points in the workflow (pre-examinations, on-site examinations and off-site examinations or monitoring) to screen and review institutions. Primarily, the MMC intends to use this technology to “pre-screen” portfolios prior to the start of examinations to better allocate examination team resources. By pre-screening the entire portfolio via an electronic upload of transaction data, the Examiner-In-Charge (EIC) can adequately prepare for the time allocated to the examination, and make the best file review selection prior to an on-site visit.

In practice, the EIC will instruct licensees to upload file data before an onsite examination is scheduled to begin. The electronic upload is then run through ComplianceAnalyzer®, automated compliance system from ComplianceEase, which reviews the data for violations of federal and state laws and regulations. Using reports generated by the software, the EIC can determine which files will be reviewed using traditional methods during the onsite examination.

The MMC is employing the following automated tools for multi‐state examinations:

  • RegulatorConnect® portal for licensees to prepare the electronic data and deliver to the EIC
  • RegulatorDirect® for licensees to deliver ComplianceAnalyzer® reports to the EIC (for licensees already using ComplianceAnalyzer®)
  • ComplianceAnalyzer® with TRID Monitor™ software for examiners to perform loan‐level audits
  • Examination Dashboard report for the EIC to review a licensee’s risk profile and overall trend analysis
Advanced Offsite Reviews and Limited Scope Visits
The same technology that allows a more complete review also provides the tools necessary for sophisticated offsite reviews which when necessary may be accompanied by limited scope visits. The MMC will establish a protocol for offsite institution monitoring through electronic data uploads, document imaging and examiner desk review. A few states are currently pursuing pilot programs of offsite monitoring. The MMC will incorporate the methods of these programs into its national protocol for offsite monitoring.
 
Single State Exams
Although the NCA and associated processes are focused on multi‐state examinations, the MMC encourages standardization and uniformity for all state mortgage examinations. Uniform approaches and standardized methods of examination are as relevant for a single state as when a state joins efforts with other states.
Lending Examination Format (LEF)
ComplianceEase's work with state banking and mortgage regulators focuses on helping CSBS and AARMR achieve their goals of increasing uniformity and efficiency in mortgage examinations. As a result, ComplianceEase has developd a number of technology tools to assist examiners with the collection and auditing of loan information.

From the commencement of the automated examination initiative ComplianceEase, CSBS and AARMR planned to start by working directly with licensees to assist in the collection of necessary electronic data for examinations. As a logical next step that required no additional technical work from any licensee or provider, ComplianceEase worked to leverage its existing integration with industry technology providers to further facilitate data collection for licensees. The final step was to devise a file format that could be used by licensees via technology platforms to collect and submit loan information for automated examinations.

The file format, called the Lending Examination Format (LEF), is available for license free-of-charge to qualified entities. State-regulated financial institutions (Licensees) can license the LEF for use in formatting and transmitting loan-level data required for use in the automated regulatory examination process. In addition, contractors and consultants hired by Licensees can also license the LEF for the same purposes when assisting a Licensee.

Technology vendors providing systems that retain the loan data necessary for automated examinations can license the LEF to provide software components and functionality that assist Licensees in formatting and exporting loan-level data for transmission to regulators as part of the automated regulatory examination process.
LEF Licensing
The file format, called the Lending Examination Format (LEF), is available for license free-of-charge to qualified entities. State-regulated financial institutions (Licensees) can license the LEF for use in formatting and transmitting loan-level data required for use in the automated regulatory examination process. In addition, contractors and consultants hired by Licensees can also license the LEF for the same purposes when assisting a Licensee.

Technology vendors, service providers and consultants providing services to the mortgage industry can license the LEF to provide software components and functionality that assist Licensees in formatting and exporting loan-level data for transmission to regulators as part of the automated regulatory examination process.
 
Although not yet included in the RegulatorConnect Certification program (RC Certify), the LEF specification available for download includes the most recent published version and is available for building LEF data exports. This specification is version 4.9, dated 03/30/2016 and includes support for loans governed by the TILA-RESPA Integrated Disclosure (TRID or Know Before You Owe) regulations.  This is the only version of the LEF specification that can be used to submit such loans for examinations.
RegulatorConnect Certification
Technology vendors that wish to demonstrate to customers and other industry participants that the functionality they have developed has been verified by a trusted third-party to properly format and export loan-level data for transmission to regulators may elect to subscribe to the optional RegulatorConnect Certification program (RC Certify). Certification is available to all technology vendors, whether or not they are technology partners with ComplianceEase.

RegulatorConnect Certified Export
Certification candidates that are not already ComplianceEase partners may utilize the LEF format to build functionality that qualifies for “RegulatorConnect Certified Export” certification. Candidates license the LEF format and build the necessary software components and functionality to export loan data from their software system to the LEF format. Along the way candidates can receive technical support and assistance as they build their LEF functionality. Ultimately, candidates demonstrate that they have constructed proper export functionality, which includes inputting predefined test loan files into their system and exporting a valid LEF. If certification is successful, the candidates may refer to their system as a “RegulatorConnect Certified Export” and will be listed in the RC Certify Directory, a listing of all RegulatorConnect Certified entities.
 
RegulatorConnect Integrated Partner
ComplianceEase's technology partners may leverage commercial integrations and exports that they build in conjunction with their partnership to qualify for “RegulatorConnect Integrated Partner” certification. Candidates utilize ComplianceEase’s commercial integration specifications to build the necessary software components and functionality to integrate with ComplianceEase products and export loan data from their software system. Partners can receive technical support and assistance through the technology partnership program. Partners demonstrate that they have constructed proper functionality, which includes inputting predefined test loan files into their system and exporting valid files. If certification is successful, the candidates may refer to themselves as a “RegulatorConnect Integrated Partner” and will be listed in the RC Certify Directory, a listing of all RegulatorConnect Certified entities.

Currently, RC Certification covers LEF exports built on version 4.50 of the LEF specification, dated September 22, 2015. Please note that this version of the LEF specification does not include support for loans governed by the TILA-RESPA Integrated Disclosure (TRID or Know Before You Owe) regulations and should not be used to submit such loans for examinations.

RegulatorConnect Technical Support and Consulting

Partners enrolled in the RegulatorConnect Certification Program using the LEF format to build export functionality into their software systems will be provisioned access to technical support. Applicants that are not enrolled in the RegulatorConnect Certification Program and are seeking assistance will be subject to our RegulatorConnect Technical Support and Consulting services fees.

Various hourly packages are available for purchase. Please select Order Services under the Optional Services menu for more details.


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