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Compliance Checklist

Marketing Compliance Checklist for Loan Officer Training and Oversight

Mortgage companies know that ensuring compliance with regulations across all loan officers can be a difficult and daunting task. The best way to get out ahead of regulatory risk is to build a robust compliance program that includes strong loan officer training and oversight processes.

We've got you covered.

Use this checklist to help shape your organization’s compliance program—from loan officer onboarding, training, and education to compliance monitoring, remediation, and technology—to ensure your loan officers are compliant in all of their marketing communications.

Let's get started

Loan Officer Onboarding

Provide documentation and ensure loan officers have a clear understanding of:

Mortgage-specific regulations, including both federal and state-level regulations

Provide a list of regulatory requirements for their social media sites, including:

Company name and NMLS number

NMLS Consumer Access link

Loan officer’s name and NMLS number

Equal Housing Lender statement or logo

Company brand guidelines

Guidelines for communicating with consumers on social media accounts

Review and approval process for content

Importance of compliance and the consequences of non-compliance

Training and Education

Regularly review and update the company's social media policy and compliance training to stay current with changes in regulations and emerging risks by:

Staying up-to-date on the latest regulatory trends in the mortgage industry through:

Regulatory agency websites, such as the Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), and Department of Housing and Urban Development (HUD)

Industry publications, such as Mortgage News Daily and National Mortgage News

Professional associations and organizations, such as the Mortgage Bankers Association (MBA) and the National Association of Mortgage Professionals (NAMP)

Joining the COMPLY Mortgage Regulatory Compliance Community

Utilize industry resources such as webinars, workshops, and conferences to stay current on emerging social media compliance issues

Conduct regular internal compliance training programs for loan officers, which includes:

Review of the company's current social media policy and guidelines for compliance

Specifically highlight any updates from previous training session(s)

Recent enforcement actions by regulators and the compliance takeaways from them

Social media best practices and resources to stay current on social media compliance regulations

New or emerging social media platforms and how to ensure compliance on them

Demonstrate examples of successful/compliant social campaigns to run vs. noncompliant social posts (here are a few examples to start)

Provide compliance-approved social media templates

Discuss prohibited content and actions, such as making misleading or false statements or using unapproved advertising materials

Emphasize the importance of transparency and the disclosure of important loan terms and features on social media platforms

Provide guidance on disclosing important loan terms and features, such as annual percentage rate (APR) and fees, and making sure that disclosures are clear and conspicuous

How to properly respond to social media complaints or negative reviews, and what type of language to avoid using

Enforcement and Remediation

Have a clear action plan for instances of non-compliance by a loan officer. This may include:

Notify the loan officer of the violation and remind them of the company’s social media policy and regulatory obligations

Removal or remediation of non-compliant content

Document instances of non-compliance and remediation by the loan officer

Determine appropriate disciplinary actions for loan officers who repeatedly engage in non-compliant behavior

Monitoring + Auditing

Have a system in place to monitor:

Multiple platforms that loan officers may be using, including (but not limited to):

Facebook

Twitter

Instagram

TikTok

YouTube

Nextdoor

Zillow

Trulia

Yelp

Personal blogs or websites

Email marketing (including email signatures)

Content of posts and flag for missing or inaccurate information, including:

Missing NMLS #

Direct mention of mortgage rates (instead of linking to an updated website page)

Inappropriate superlatives

Urgency abuse

Offerings that have not been created or approved by the company

Technology

Implement a social media compliance software or tool to help monitor loan officer's social media activity and ensure compliance with regulations that includes:

Automatic discovery of your brand and loan officers across the web and on social platforms

Ongoing monitoring across the web and most prevalent social media platforms

OCR capabilities to review and score the text from within any image shared in a social post

Ready-to-use (but customizable) mortgage industry rulebooks to monitor content against

Public use information obtained from NMLS® Consumer AccessSM for fast and easy onboarding and continuously updated LO review

Centralized workflow that tracks activities across loan officers, internal departments and external partners

Detailed reporting and analytics for compliance and performance

Archived history from discovery through remediation for any audit situation

Scalable platform that makes it easy to add additional marketing channels for review and monitoring, including the web, calls, messages, emails, and documents

The #1 Social Media Compliance Monitoring Platform for Mortgage Companies

Is social media the bane of your existence? We get it.

PerformLine's omni-channel compliance monitoring technology automates...

Marketing compliance review and approval process of loan officers' content
Ongoing monitoring of loan officers' social accounts across multiple platforms including TikTok, Twitter, LinkedIn, Facebook, Instagram, and YouTube
Discovery of unknown or unapproved loan officer vanity URLs

...to make loan officer oversight streamlined, efficient, and painless.

Get complete compliance coverage with PerformLine

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