8-hour safe comprehensive ce course #3367 compliance ......quizzes and exams are administered...

1 © 2013-2014 CMPS Institute. All Rights Reserved. // NMLS Provider ID # 1400384

8-Hour SAFE Comprehensive CE Course #3367 Compliance Blueprint for the Pre-Disclosure Sales Process || Course Syllabus This course is divided into four modules that meet all 8 hours of NMLS requirements for continuing education under the SAFE Act. (One hour is defined as 50 minutes of video content per the NMLS Guidelines.) Module 1 – Compliance Blueprint for the Pre-disclosure Sales Process (Part 1) - 2 hrs

• Two hours of Federal Law Module 2 – Compliance Blueprint for the Pre-disclosure Sales Process (Part 2) - 2 hrs

• One hour federal law • One hour Elective

Module 3 – Compliance Blueprint for BSA-AML - 2 hrs

• Two hours of Ethics Module 4 – Compliance Blueprint for Non-Owner Occupied (NOO) Loans - 2 hrs

• Two hours of Nontraditional Mortgage The method for studying the curriculum is to:

• Watch 8 hours of online videos (4 distinct modules) • Take a series of online quizzes as you move through the modules • Take a final module exam at the end of each module (70% passing grade

required to advance to the next module) • Take a final online exam at the end of the course (70% passing grade required to

pass the course) • In order to complete the course you will be asked to complete a course survey

Course Workbook You may print out the course workbook (provided in .pdf format) and use it as a guideline for following the instructor and taking comprehensive notes as you go through the training. There are fill-in the blank spaces within the workbook to keep you engaged. This will enable you to get the most from the information and personalize the knowledge that you will gain. There are also links to various websites listed throughout the course workbook. The links are only accessible if you are viewing the document as a .pdf.


Technical Requirements • A computer that has an internet connection and audio / visual capabilities

How do the exams work? As you go through the curriculum, you will be quizzed and tested on the materials. The quizzes and exams are administered through an online test‐as‐you‐go format. They are graded in “real time,” and you’ll know if you pass immediately upon completion. In order to graduate from the course, you must:

1. Get a 70% passing grade on each of 4 final module exams (each exam is graded separately); and,

2. Get a 70% passing grade on the final course exam.

…………………………………..

• There are 20-23 sections per module (up to 5 minutes of video per section). • Once you’ve gone through all the sections in a module, you will be placed into a

5-question Final Module Exam that you must pass with a 70% passing grade.


• You must answer a quiz question at the end of each section. • You must receive at least a 70% passing grade (4 out of 5 questions) on the final

module exam in order to advance to the next module. • If you do not pass the final module exam, you will be given two additional re-tries • If you do not pass the final module exam after three attempts, you will be taken

back to the beginning of that two-hour module and you’ll be required to retake that module in its entirety (videos, quizzes and final module exam)

Example: Final Course Exam

• After you pass all 4 final module exams, you will have a 25-question final course

exam. • You must receive a 70% passing grade (18 out of 25 questions) on the final

course exam in order to pass this course and receive your NMLS CE credits. The Final Course Exam:

• If you pass the Final Course Exam, you will have completed the course and you will receive 8 hours of continuing education credit under the SAFE Act and NMLS guidelines.

• If you do not pass the Final Course Exam, you can take the exam two more times. If you do not pass the Final Course exam with those two attempts, we ask that you go back and study the entire curriculum again. After 30 days, contact us or return to the site and purchase an Extra Exam Try for $59.

Special Note: Once you complete the entire course you will be able to view the full video modules for up to one year after you have purchased the course. (For example, if you purchase the course on January 1, 2014, and pass the course on March 1, 2014, you will be able to view the full video modules until December 31, 2014.)

Module 1 Module 2 Module 3 Module 4 25 Ques/on Final Course

Exam


About the Instructor

Gibran Nicholas, CMPS® Chairman & CEO CMPS Institute

Gibran Nicholas is a professional writer, speaker and an entrepreneur. Gibran speaks and writes about economics, real estate and financial issues including the current mortgage and credit crises. Since 2005, he has been the Chairman and CEO of the CMPS Institute, a national organization that certifies mortgage bankers and brokers. Gibran has personally trained over 7,000 entrepreneurs and trusted advisors. Gibran is regularly quoted as a financial and housing expert in national publications such as the Wall Street Journal, Barron's, MarketWatch, Business Week and the Washington Post and has been featured on Fox and ABC News. Gibran is an old-timer in the world of entrepreneurs. At 16 years old he entered law school, and at 20 years old, he started his own mortgage planning firm. The business quickly became one of the highest volume private mortgage companies in Michigan, with additional licenses in Illinois, Florida, and Massachusetts. In 2005, Gibran became the Chairman and CEO of the CMPS Institute. Through his involvement in CMPS, Gibran empowers mortgage and financial professionals with knowledge and resources to better serve clients and increase their competitive advantage. Gibran has served as a board member for the Financial Planning Association of Michigan, and is very active in the financial planning community. He frequently teaches continuing education seminars for CPAs, Certified Financial Planners, attorneys, real estate brokers, and mortgage lending professionals.


Module 1 – Compliance Blueprint for the Pre-disclosure Sales Process (Part 1) Instructor: Gibran Nicholas Time: 2 Hours Learning Objectives:

• What can be said and/or communicated with prospects, borrowers and referral partners during the pre-disclosure sales process according to Reg. N and Reg. Z

o Phone conversations o Face-to-face conversations o Seminars and workshops o Emails o Videos o Social media o Print

• Record-keeping requirements under Reg. N and Reg. Z o Which records must you keep? o How long must you keep them? o What formats are acceptable?

Outline: Introduction (approx. 20 minutes)

• The pre-disclosure sales process: what it is, why it matters • Regulatory trends in the mortgage sales process

o Dodd-Frank issues to watch out for in coming months and why they matter; including:

§ Risk retention § Qualified residential mortgage (QRM) § Loan originator compensation

o CFPB proposed rules and rule-making process o CFPB final rules o CFPB inherited regulations o State laws regarding the pre-disclosure sales process: how to find them

and why they matter


Compliance Checklist & Regulation N (approx. 45 minutes) • How to use the “Compliance Checklist” located in your workbook to double-check

yourself for compliance with Reg. N during the pre-disclosure sales process • Definition of “commercial communication” and why it matters • How to advertise yourself and what types of communications to avoid

o Instructions o Interactive examples and case studies

• How to advertise your loan products and what types of communications to avoid o Instructions o Interactive examples and case studies

• How to keep records o Which records must you keep? o How long must you keep them? o What formats are acceptable?

Compliance Checklist & Regulation Z (45 minutes)

• How to use the “Compliance Checklist” located in your workbook to double-check yourself for compliance with Reg. Z during the pre-disclosure sales process

• Definition of “commercial messages” and why it matters • Key exceptions to Reg. Z advertising rules and why they matter • How to follow the general advertising rules of Reg. Z and what types of

communications to avoid o Instructions o Interactive examples and case studies

• How to understand and follow the rules involving “trigger terms” o Instructions o Interactive examples and case studies

• Seven prohibited advertising practices and how to avoid them Module 1 - Final Module Exam

• Five (5) quiz questions with a 70% passing grade • You must answer 4 out of 5 questions correct in order to advance to the next

module


Module 2 – Compliance Blueprint for the Pre-disclosure Sales Process (Part 2) Instructor: Gibran Nicholas Time: 2 Hours Learning Objectives:

• Compliance requirements for the prospecting and advertising stage of the loan process

o How to understand and follow the do-not-call, do-not-fax and do-not-SPAM rules

o How understand and follow Reg. X rules relating to the pre-disclosure sales process

o How to understand and follow the Reg. V rules relating to the pre-disclosure sales process

o How to avoid the implication of government agency in your advertising and why it matters

• Compliance requirements for the sales conversation stage of the loan process o How understand and follow Reg. N rules relating to sales conversations o How to understand and follow the Reg. Z rules relating to sales

conversations o How to understand and follow the Reg. B rules relating to sales

conversations o How to understand and follow the Reg. X rules relating to sales

conversations o How to understand and follow the Reg. V rules relating to sales

conversations Outline: Introduction & FTC/FCC Rules (approx. 45 minutes)

• How to comply with the do-not-call rules • How to comply with the do-not-fax rules • How to comply with the do-not-spam rules • Record-keeping requirements


Reg. X and Reg. V Rules Regarding Lead-Buying (approx. 15 minutes) • Rules about paying “success fees” to marketing agents • Rules about buying leads from a credit bureau

o Rules surrounding firm offers of credit, short notices and long notices under FCRA

Implying Federal Agency in Your Marketing (approx. 10 minutes)

• Practices to avoid under 18 USC § 709 and FHA mortgagee letter 11-17 Reg. N, Reg. X, Reg. Z, Reg. B and FCRA Rules Regarding the Sales Conversation (approx. 25 minutes)

• When a sales conversation crosses the threshold into a formal application under Reg. X and Reg. Z, and why it matters

• When a sales conversation crosses the threshold into a formal application under Reg. B, and why it matters

• What you can and can’t talk about in a sales conversation according to Reg. B • When a sales conversation crosses the threshold into a formal application under

FCRA, and why it matters • When you are allowed to pull a credit report and the compliance risks you are

taking when you do so without a signed written authorization from the borrower Compliance Checklist & Implementation (approx. 10 minutes)

• How to use the “Compliance Checklist” located in your workbook to double-check yourself for compliance during the pre-disclosure sales process

• How to train your staff and assistants to follow legally compliant procedures during all phone, email and other communication with prospects and borrowers

• How to build proper systems of legal compliance whether you use a transactional model (buying leads) or relational model (referral partners) of doing business

Module 2 - Final Module Exam


module


Module 3 – Compliance Blueprint for BSA-AML Instructor: Gibran Nicholas Time: 2 Hours Learning Objectives:

• Compliance requirements under the Anti-Money Laundering (AML) provisions of Bank Secrecy Act (BSA)

• Key definitions under the Bank Secrecy Act (BSA) and why they matter • Which anti-money laundering (AML) procedures need to be implemented • Mortgage fraud red flags and:

o How to assess the risks of money laundering with your products and services

o How to develop policies and procedures to mitigate the risk o How to file suspicious activity reports (SAR)

• Which reports need to be filed under the BSA-AML rules and when/how to file them

• Which records need to be maintained under the BSA-AML rules, and how to maintain them

Outline: Intro, Key Definitions under BSA-AML, and Anti-Money Laundering Procedures (approx. 15 minutes)

• Who is required to comply with the rules • Where to find information about compliance requirements • How to develop and implement a written anti-money laundering program • The four pillars / minimum requirements of your program

o How to develop written policies and procedures o How to designate a compliance officer o How to engage your team in ongoing training o How to test your systems for compliance


Mortgage Fraud Red Flags (approx. 30 minutes) • The geographic locations where mortgage fraud is most prevalent in today’s

market • The types of mortgage fraud that are most prevalent in today’s market, and how

to spot them • Red flags and interactive case studies involving mortgage fraud • How to assess the risks of mortgage fraud and how to develop policies and

procedures to mitigate the risk Suspicious Activity Reports (SARs) and Requirements (approx. 15 minutes)

• What reports you need to file • Where you need to file the reports • When you need to file the reports • Record-keeping requirements when you file SARs • Confidentiality requirements and why they matter

Record Keeping Requirements under BSA-AML (approx. 20 minutes)

• What types of records you must keep and how to keep them • How to handle transactions involving foreign buyers (which represent 9% of all

home sales in the US) • How to handle transmittals over $3,000

Eight Case Studies for BSA-AML (approx. 30 minutes)

• What types of records you must keep and how to keep them • How to handle transactions involving foreign buyers (which represent 9% of all

home sales in the US) • How to handle transmittals over $3,000



module


Module 4 – Compliance Blueprint for Non-Owner Occupied Loans Instructor: Gibran Nicholas Time: 2 Hours Learning Objectives:

• Two out of every ten home sales in today’s market are non-owner occupied. Also, occupancy fraud is one of the most prevalent forms of mortgage fraud. Learn:

o How to understand and follow FNMA, FHA and VA guidelines regarding primary residence occupancy

o How to understand and follow FNMA guidelines regarding vacation homes o How to understand and follow FNMA guidelines regarding limitations on

number of financed properties o How to understand and follow FNMA guidelines regarding NOO loans

Outline: Introduction & FNMA Primary Residence Occupancy Rules (approx. 35 minutes)

• Trends in the non-owner occupied marketplace • Where to find the rules governing occupancy for FNMA, FHA and VA loans • FNMA occupancy guidelines including:

o Non-occupant co-borrowers o Parents who provide housing for children o Children who provide housing for parents o What is required if the borrower hasn’t sold his/her old home

FHA and VA Occupancy Rules (approx. 30 minutes)

• FHA occupancy guidelines including: o Non-occupant co-borrowers o Relocation scenarios o Increase in family size scenarios o Vacating a jointly owned property

• VA occupancy guidelines including: o 60 day and 12 month rules o Interest rate reduction refinance loans (IRRRLs) o Occupancy by a spouse o Occupancy after retirement o Delayed and intermittent occupancy


o Ineligible occupancy and loan usages o How to restore eligibility

FNMA Vacation Home Rules and FNMA Eligibility Matrix (approx. 20 minutes)

• Second home eligibility requirements • How to use the FNMA eligibility matrix • Two vacation home case studies

FNMA Rules re: Investment Properties & Multiple Financed Properties (approx. 20 minutes)

• Three investment property case studies • How various types of property ownership impact eligibility under the “multiple

financed properties” rule • Reserve requirements based on number of properties financed • Four case studies for multiple financed properties


• Five (5) quiz questions with a 70% passing grade • You must answer 4 out of 5 questions correct in order to advance to the final

course exam Final Course Exam - 25 questions (20 minutes to complete)

• You must answer 18 out of 25 questions correct in order to complete the course and receive your NMLS CE credits

For more information, please contact:

CMPS Institute 3017 Walnut Ridge Dr. Ann Arbor, MI 48103

888.608.9800 [email protected]

8-hour safe comprehensive ce course #3367 compliance ......quizzes and exams are administered...

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