Compliance and Regulatory Reporting

Compliance Framework

Marcus Naulin maintains a written Compliance Management System ("CMS") consistent with guidance from the Consumer Financial Protection Bureau, the Office of the Comptroller of the Currency, the Federal Trade Commission, the California Department of Real Estate, the California Department of Financial Protection and Innovation, and analogous state regulators. The CMS includes board oversight (where applicable), policies and procedures, training, monitoring and audit, consumer-complaint management, and corrective action.

Topics Covered by the CMS

• Truth in Lending Act / Regulation Z (including loan-originator compensation, advertising, ATR/QM, HOEPA, ARM disclosures).
• Real Estate Settlement Procedures Act / Regulation X (Loan Estimate, Closing Disclosure, escrow, mortgage servicing).
• Equal Credit Opportunity Act / Regulation B (adverse action, valuation independence, anti-discrimination).
• Home Mortgage Disclosure Act / Regulation C (LAR submission, public-disclosure statement).
• SAFE Act and state mortgage licensing requirements.
• Fair Housing Act and state fair-housing laws.
• Bank Secrecy Act and Office of Foreign Assets Control screening.
• Gramm–Leach–Bliley Act privacy and Safeguards Rule.
• Telephone Consumer Protection Act, CAN-SPAM, and state mini-TCPA statutes.
• State unfair-or-deceptive-acts-and-practices statutes (UDAP/UDAAP).
• Recordkeeping requirements applicable to mortgage and real-estate licensees.

Vendor Risk Management

We perform initial and periodic due diligence on all third-party service providers including review of: licensure, regulatory history, financial condition, information-security posture, fair-lending practices, and complaint history. Each provider operates under a written contract that imposes appropriate confidentiality, data-protection, indemnification, audit, and termination provisions.

Consumer Reporting and Furnishing

We do not directly furnish information to consumer reporting agencies but may facilitate furnishing through lender partners. We require all furnishers to comply with the Fair Credit Reporting Act, 15 U.S.C. §§ 1681 et seq., and Regulation V, including investigation of consumer disputes within thirty (30) days.

HMDA Public Disclosure

HMDA data is reported annually to the appropriate federal regulator. The disclosure statement and modified Loan Application Register are available to the public through the Federal Financial Institutions Examination Council at ffiec.cfpb.gov/data-publication.

Suspicious Activity Reporting

Where required, suspicious activity is reported to the Financial Crimes Enforcement Network (FinCEN) at fincen.gov in accordance with 31 C.F.R. Part 1010. SARs and the existence of any SAR are confidential and may not be disclosed to any party identified in a SAR.

Record Retention

We retain records consistent with the schedules in our Privacy Policy and as required by RESPA, ECOA, HMDA, BSA, and applicable state law. Originals or accurate reproductions are retained for the longer of any applicable retention period or any active legal hold.

Regulator and Examiner Cooperation

We cooperate fully with examinations, supervisory reviews, and investigations conducted by federal, state, and local regulators having jurisdiction over our activities. Documents and information requested by regulators are produced consistent with applicable confidentiality obligations and legal privileges.

Annual Compliance Review

The CMS is reviewed at least annually. Updates address regulatory changes, examination findings, complaint trends, technology developments, and lessons learned from incidents.

Contact Us