Our society’s attitude towards consumer financial products has fundamentally changed since the mortgage meltdown. A key component of this change is a role for the federal government to actively regulate industries where it feels consumers can be easily harmed. While it may not have appeared to the ARM industry that it was being ignored by the regulators, other industries may have actually received more attention. Looking at the mortgage industry’s travails may help the ARM industry to avoid some of the pitfalls.
A new whitepaper from Baker Tilly, “Lessons Learned for the ARM Industry from the Mortgage Meltdown,” (download here) examines five important lessons players in the ARM industry can take from the mistakes made by others.
Here is an excerpt from the whitepaper:
3. Make your internal compliance program “ready for the external spotlight”
Regulator attention and reporting can become a bright spotlight on your back office and internal documentation if your compliance program is not working. To many observers, the concept of creating documentation for internal processes appears bureaucratic. This is understandable given that few companies actually sell policies and procedures – they sell other stuff which almost always appears sexier. However, we would argue that a well-documented compliance program would serve you well internally and then with your regulator. First, the process to draft and/or update your compliance program can serve as a catalyst for re-thinking your program, surfacing issues, and addressing challenges. Despite all the technology advances we have had, the best way to make sure you are on the same wavelength as others is to write it down. Second, these types of documents are no longer strictly internal ones – at best they are “semi-private” in that they will serve as the first impression for your regulator. If your regulator has an issue with your compliance program, it could become public.