"What are examples of some approaches or methods that you might recommend to improve the supervision of business conduct in Mortgage Brokerages?"
- Regular performance reviews.
- Prior to paying a Mortgage Agent, audit his/her files to make sure they are in compliance. This audit should check for fraud and any items that look suspicious.
- Review all deals closely.
- Monitor private funds.
- Conduct spot audits of files as Mortgage Brokers/Agents work on them to ensure compliance.
- Develop a policies and procedures manual for Mortgage Brokers, Agents and support staff.
- The Mortgage Brokerage should approve all public relations and marketing materials.
- The Principal Broker should approve and have copies of all correspondence going to the public.
- Create a trade record form that needs to be included in all mortgage files.
- Require the Principal Broker to review each file and check that it complies with documentary and suitability requirements.
- Ensure Mortgage Brokers and Agents continue taking education courses.