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The Three Percent Solution

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Th e M Rep o RT | 27 Feature Th e M Rep o RT | 27 L enders seem to rarely consider what sort of impacts the adoption of strong human resources programs can have on the mortgage industry. But now they would be wise to take into account the overwhelmingly positive effects of carefully calibrated initiatives— especially in this increasingly rigorous regulatory environment. Overlooked, even often deemed trivial, sound HR policies and well-executed employee train- ing programs are, in fact, essential to ensuring everything from fewer compliance problems to healthier working relationships between lenders and their vendors. Within an industry that depends so heavily on strong professional rela- tionships, attention must be paid, to paraphrase the playwright Arthur Miller. Treasury's Office of the Comptroller of the Currency (OCC) has put it plainly: Lenders are now wholly responsible for the actions of any third-party providers with which they do business. Those vendors' corporate train- ing programs are as much the responsibility of lenders as anyone else. So before entering into a business agreement, originators and servicers must ensure that both they and their vendors are incorporating certain key HR components into healthy employee training programs. And it is vital that those programs cover the most important issues the mortgage industry faces: compliance, ethical business practices, and secu- rity awareness. Compliance training should be first and fore- most in every vendor training program. Consider the new business environment cre- ated by the OCC, Fannie Mae's Uniform Loan Delivery Dataset, and Regulation B (the equal credit opportunity mandate). Each has added another layer of complexity to originating loans. Such regulations have forced lenders to proactively guard themselves by partnering with trusted vendors who employ full-time compliance staffs dedicated to the daily monitoring and interpreting of the latest local, state, and national rules. Lenders must insist that their vendors have thorough compliance training programs to avoid employee dismissals and legal trouble, create a cohesive workplace, and protect the company if an employee ever violates a rule regardless of the training provided. It is critical for the HR and compliance departments to work together to educate employees on inter- nal and external regulations and policies that apply to work responsibilities. An internal training program should not be lim- ited to new associates. All employees should be re- quired to take an intense and thorough compliance training seminar, as well as continue to regularly enroll in ongoing training courses. Management can—and should—employ a system to track train- ing, not only notifying employees of upcoming mandatory instruction, but also alerting manage- ment to the completion of the program by every employee. Manuals for easy reference can bolster online courses if questions arise after training. Furthermore, creating a vendor oversight com- mittee should aid in compliance by constantly monitoring the performance of third-party From the Inside Out Lenders and vendors can build stronger relationships through robust human resources programs. By Yvonne Thompson, vice president of human resources at LRES

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