ACUMA ONpoint
ACUMA ONpoint
Your 30-Year Compliance Relationship Begins After Closing
Mortgage servicing compliance represents one of the most overlooked yet critically important aspects of credit union operations today. In this revealing conversation with Scott Weintraub, VP of Compliance at MQMR, we explore why credit unions often shortchange their servicing compliance resources despite the 30-year relationship at stake.
Scott shares his journey from law to mortgage compliance, explaining how his passion for helping companies comply drives him to educate credit unions about servicing risks. As he points out, "The servicing relationship could last decades, yet if there are resources allocated to compliance, it tends to be much more on the origination side."
This imbalance creates significant vulnerabilities in five key areas.
- Escrow administration requires annual analysis and proper handling of shortages or surpluses.
- Customer service standards must meet regulatory expectations even for borrowers not in default.
- Loss mitigation processes demand consistent treatment of applications and decisions.
- Fee assessment and waiver policies must be applied fairly across all member segments.
- Fair servicing practices - a concept many credit unions don't realize exists - require vigilant monitoring.
These areas are particularly dangerous because examiners consistently flag them during audits, looking not just for documented policies but evidence that these policies match actual practices. As Scott emphasizes, "The lack of a sufficient QC program is a finding that's very common."
The solution builds on two fundamental principles:
- Comprehensively understand your servicing obligations
- Regularly examine your operations.
This approach transforms "unknowable risk"—the worst possible position—into manageable, addressable issues.
Ready to strengthen your credit union's servicing compliance? Tune in now to get the latest.
Sponsored by Consolidated Analytics
The views and opinions expressed in this podcast do not necessarily reflect the views or positions of Acuma, its board of directors, its management staff or its members. The podcast discussion presented is conversational in nature and for general information only.
Speaker 2:Hello and welcome to Aqua's On Point Podcast, a series focused on sharing the stories of people who are making a positive impact in the credit union mortgage industry. I'm your host, Peter Benjamin. Before we get to our episode, just a quick word from our sponsor.
Speaker 3:This episode is brought to you by Consolidated Analytics, helping credit unions make smarter mortgage decisions, from origination to servicing and beyond, with expert valuation, risk management and compliance solutions. They provide the insights you need to protect your members and grow your portfolio with confidence. Whether it's due diligence or a collateral risk assessment, they help you navigate the market with ease. Learn more at due diligence or a collateral risk assessment. They help you navigate the market with ease. Learn more at consolidatedanalyticscom.
Speaker 2:Welcome to the fourth episode of our compliance miniseries, where each episode will feature an intimate conversation with people who I consider to be experts in the field and supporters of the credit union movement. As a reminder, with each of these episodes, it's our goal to take a deep dive into various compliance topics that are impacting and reshaping the credit union mortgage industry. Our next guest in the compliance miniseries is Scott Weintraub, Vice President of Compliance with MQMR. Scott, how are you doing today?
Speaker 4:I'm doing great, peter. I'm so excited to be on with you and Acuma, so thanks so much for having me on.
Speaker 2:No, it's our pleasure. We couldn't be more thrilled to have you here One because we've had the opportunity of getting to know you through our relationship with MQMR, having MQMR be an AppGift service provider. You recently attended our workshop in Seattle. You are one of our moderators for our servicing network, so we've gotten a chance to know you. So we're really excited to sit down with you and have this conversation. But before we really dive in and get to know you a bit more and really talk, compliance, as always, got to bring Justin in. And here's the latest and greatest happening over at Acuna Hawk. What's going on? How are you doing today? And please, please, tell us what is the latest greatest happening over at Acuna. I'm good, Peter.
Speaker 5:How are you Living the dream. I love it, awesome. So over here at Acuna, we are mid planning or not not even planning we're mid getting ready to come out to Denver for our Make your Mark annual conference, which is set to take place on September 21st to the 24th. So we're what are we like eight weeks away now? Roughly Right, something like that. Yeah, something like that. So the speakers in the agenda are jam-packed with experts in the mortgage industry.
Speaker 5:I'm certain that if you come to the event, it's going to be one you don't want to miss, and if you aren't coming, then you're going to be so sad because you're going to miss the biggest event for credit union mortgage professionals in the fall. Registration's open, so head over to the ACME website and come make your mark with us in Denver. We can't wait to see you. Aside from our annual conference, if you're looking for additional networking and educational opportunities, we have our next network meeting, the Volume-Based Network. They're going to have their Q3 meeting in August, just a few weeks away. So information's already up on the website. So head over there and learn more and register. And then our webinar series, the Fast Tracks and Inside Tracks, and our On Point podcast, which helps keep the fun and learning going all year round.
Speaker 2:All right, all right. It's going to be awesome. Can't wait for annual Annual is going to be probably the best one yet. Best agenda, best speakers. Couldn't be more excited for it. It's going to be spectacular.
Speaker 5:I mean, you've already said it this is probably the best one that you put together in your time at Acumen. I mean hands down.
Speaker 2:I mean, this is going to be something very, very, very special.
Speaker 5:Yes, looking forward to it.
Speaker 2:All right, we can't wait, that's for sure. I, yes looking forward to it. All right, we can't wait, that's for sure. I love it, I love. All right, sorry, all right, scott. Uh, oh, justin, thank you very much. No, scott, all right. Turning over our sights back to you.
Speaker 2:You know, the actual employee podcast is a people piece. I mentioned that in my opening statement. You know I always say this. I always go through the same, you know introduction, the first question and the last question is always the same. You know, it's about diving into who our speakers are, getting to know them on a more personal level before we actually really focus on the main topic. And so the first question is always you know who is Scott, or who is the speaker? Because I think that's the most important thing about all of us what makes us tick, what makes us who we are? We're more than mortgage professionals. We're more than the president of Mac. We're more than the director of marketing for Actima. We're more than everything. So I think that's the most important question. I ask you all day today who is Scott? So do me a favor, walk us through that. And then, of course, we'll dive into our compliance miniseries. So, first question who's Scott?
Speaker 4:Absolutely, Peter. First of all, thanks for asking, and I think my journey is an interesting one. To where I got today. I'll start with, I imagine, like many people that you've talked to or who are in this industry, I did not, from the time I was a kid, say if only I could grow up and work in regulatory compliance in the mortgage industry, right then all my dreams would come true. I didn't start out that way, but I'll tell you I was born in Nebraska and apparently I admit that out loud. But I spent most of my childhood growing up in Southern California, which is where I live now and I can't imagine living anywhere else. And then I went up to college in the Bay Area and then out to Washington DC for law school.
Speaker 4:After law school I spent a couple of years at a law firm and found very quickly that that wasn't for me. I liked the work, I didn't like the environment and that law firm didn't deal in mortgage at all. It dealt mostly in health insurance and in defense and didn't really lead to sleeping well at night. So, Peter, I saw an ad for a job in-house with a mortgage company and it said you needed two things. One was three to five years experience in reading laws and interpreting them and knowing how to comply with them. Well, that I had. Then, of course, it said you needed three to five years experience in the mortgage industry, to which I said, well, I have none, but maybe whoever's doing the hiring might know that that part. You could learn right what a mortgage is and how that works, and maybe I could convince them that my learning curve would be short.
Speaker 4:Well, fortunately for me, that's exactly what happened, and that was back in 2003.
Speaker 4:So now we're going on 22 years where I've been in the mortgage industry ever since and couldn't be happier about it exclusively doing legal and regulatory compliance.
Speaker 4:So that involved working at a few different over the last 17 years before I got to MQMR a few different lenders and servicers. That included a servicer that really all they did was service loans, and then some lenders who originated loans and either service loans as well in-house, or had oversight and management responsibilities over a subservicer who serviced the loans for them. So I've had a lot of experience both ways, with servicing in-house and managing a subservicer who's doing the day-to-day activities. Then for the last five and a half years I've been at Mortgage Quality Management and Research, which everyone can refer to as MQMR much easier and faster, and what we do is provide consultative services right, All related to compliance, risk management and audit, and so we help lenders, and particularly servicers, with all aspects of compliance, of which, as you know, Peter, there are so many things, so many different entities that could come knocking on a credit union's door, and so that's what we do, that's what my journey has been.
Speaker 2:I'm very confident that I'm at my last job. We love helping companies, but in particular, I just like doing things like this, which is hopefully passing on some knowledge to your listeners. The sharing of knowledge is one of the things that makes the credit union industry so special. I think no matter who you talk to in our side, that's the first thing they always say. You know, credit union share, and the fact that that's something that you thrive in, right of wanting to help, wanting to really give back and share the knowledge that you've gained throughout all the years, that's absolutely amazing. I mean, I sensed it when we were in Seattle and you really embraced everyone in that room and all you wanted to do is, one, listen, but two, really help them learn and kind of flourish. I think it's awesome. So us, us kind of asking you and your, your willingness to kind of jump in and help facilitate again, you know that that servicing network that we have it's just only exhibits your desire to help. So so, scott, let's, let's, let's pivot and kind of talk about, you know, here we are in the compliance miniseries and last year we did the, the MI miniseries, where we really focus on, you know, the importance of MI and kind of debunking the myth.
Speaker 2:This year we decided to go with compliance because it ended up being more timely than we ever thought. We picked compliance because it's it's one, it's always been a moving target, but two, it just happened to be even more of a moving target this year than we ever thought it would be. But servicing, historically speaking, servicing has never really been something that Ackman is focused on. Yeah, we may have talked about it in passing, but servicing has just only recently been something that our members have really started focusing on. And you know, prior to this recording, you and I really started having a conversation as to why allocations when it comes to compliance professionals within credit unions, who, and really the investment of compliance professionals on the servicing side, and I'd love to get your take on that if you could. Let's start with that point. I think, of course, this is a great conversation we're going to have, so let's start with that. So what are your thoughts on just you know, credit unions allocating certain resources to compliance on the servicing side of the business?
Speaker 4:Excellent place to start, peter, and first I'd like to hit on something that you mentioned, which is what I noticed in both Seattle and Savannah, at both of the workshops this year. I think you're so right when you said that one of the things that's unique about credit unions in that space is how much they share, and I saw that firsthand, and if I could contribute, if I contributed to that conversation in any small way, I'm happy to do it and can't wait to do that even more. Another way that credit unions are unique similar a little bit similar to banks, but certainly different than a mortgage banker that that's all they do is that credit unions, they don't just make mortgages. It's certainly an important part of what they do, but it's not the entirety of what they do. And what I have found from so many conversations that I've had with credit unions is that budgets are limited, and particularly when it's related to compliance, which a lot of companies don't necessarily think that's where you make your money in compliance, I would suggest that it actually is, or by saving money, you can help your company's bottom line, but there isn't always enough resources in terms of people, dollars, systems, training, all of those different pieces to that puzzle that helps you create a compliance infrastructure.
Speaker 4:What I found with credit unions is, if there are resources that are allocated to compliance, the lion's share of it goes to the non-mortgage elements of what the credit union is doing. Of it goes to the non-mortgage elements of what the credit union is doing, much more so on the depository side with those accounts, versus specifically going to mortgage. Further, when there is allocation done time, resources, money, whatever that may be related to compliance on the mortgage side, it tends to be more on the upfront side, on the origination side, making the loan in the first place, as opposed to servicing. One of the reasons I have always wondered about that is because, as we all know, it could take 30 days, 60 days, right, maybe 90 days at the outside to originate a loan for a member. The servicing relationship could last decades, right Up to 30 years. And there are laws and when we say laws, there are many of them that a servicer would have to follow for up to a period of decades, right?
Speaker 4:And yet, if there are resources allocated related to compliance on the mortgage side, it tends to be much more upfront and not as much on the servicing side. And so, peter, the conversations I have with credit unions, I always start there what's allocated, either internally or what vendors? Might you have to help, or both? And you're right, similar to how Acuma maybe in the past, before all the great things that you're doing now, wasn't as focused on compliance on the servicing side. That was true of the credit unions themselves as well, and I think conversations that I've had with them have been very eye-opening when they've thought about some of these things.
Speaker 2:So it's interesting, right? So, if you think about it, you have some credit unions that strictly portfolio and then you have some credit unions that sell some on the secondary market and they have some that sell a whole bunch. But let's focus on the two of them that I mentioned, the ones that sell some and sell some that sell a lot. Typically, the ones that are selling on the secondary market require some form of QC plan, sell a lot. Typically, the ones that are selling on the secondary market require some form of QC plan and the QC plan does typically require them to have some. I know it's quality and not necessary compliance, but it typically requires you to have some form of standards that you must comply with, whether you are servicing retained or servicing release, it doesn't really matter.
Speaker 2:You would think that they would invest more resources into those things, but I, I, I, from what I'm seeing, it's still not the case, right? Like there's still very much falling short. Technology is just isn't up to par or up to snuff. Member service isn't still up to snuff, cause I think member service does can very much impact compliance absolutely. Uh and and now that you're saying all these things, you're right, you know, 30 year more like we're. You know we're blessed to have a 30-year mortgage. You know, and with you know, three percent paper, there's a, there's a fighting chance that we may have 30-year mortgages that actually may mature for 30 at 30 years right.
Speaker 4:Right Yep In the environment. We're in now for sure.
Speaker 2:So you are, harm's right, I never actually really sat down and thought about it the compliance risk, on this long-term effect of not investing in servicing and the the servicing resources. You're exposing yourself to a lot of things If you only, we'll say, front load your compliance resources and you totally skip over everything else. So you're bringing up a very, very good point and I think it's a good segue to really the next thing that we were going to talk about. It's really all the things that you have to focus on, right? So if you were to list, like they'll say, the top five, the top five rules, regs, acts, you name it that could potentially expose a credit union to potential harm and let's not even focus on things that an NCOA or CPV auditor is going to come and look at, but let's say that the fundamental top five, what are they?
Speaker 4:Yeah, absolutely, and I think, right before I get into that, I would just say as a general manner, you hit on a couple of things that are really important, which is there is a ton of legal and compliance risk and exposure if a company is not focused on it and doesn't have this infrastructure in place of compliance and you mentioned QC, that's an important part of it and it does get to compliance aspects, and I'm going to give some of the examples when I talk about this top five.
Speaker 4:And if you don't have a process or a system to look at some of your loans, then you're in that place that I think Peter, you and I talked about right before we jumped on in the recording, which is you're in what I consider to be the worst possible place, which is unknowable risk. If you're not looking, then you don't know where you might have a gap or a hole, and that's going to put you in a situation where a regulator someday is going to tell you where your gaps and your holes are, and then you have two problems One, the gap or the hole itself, and secondly, they will say your compliance infrastructure was not sufficient enough to have found these yourself, and so you have a general problem in addition to the specific ones, so so, so it's already, you know, is this?
Speaker 2:I'm not. I guess I'm pausing because I'm trying to think of a way to kind of frame this up. Yeah, is this all a result of the fact that a lot of the big rules or changes that our industry has gone through in recent time has all been on the front end? You know, let's think about it. You know, atrqm Yep Trade Trade on the front end. You know, let's think about it. You know atrqm yep trade trade.
Speaker 2:Um, I guess humda, for the most part, right, um, although humda really is on a servicing side, but it's the data collection points are on the front. Yep, um, elo, comp, um is. Is this because of all the major changes happened on the consumer-facing side? Although, yes, servicing does have a consumer-facing component to it, actually a major component, but that's only when there's a need, right. People often forget and in our last episode of the Compliance Miniseries, mandy Phillips with ASUS Quality Management mentioned very eloquently that people often forget that just because you are not late or in default doesn't mean you can't call or should not call your servicer, right? And so that's why people often forget that, hey, I just need to call. I need to call and have that interaction, get things updated, et cetera, et cetera, et cetera. I digress to my conversation. My question is are we, as an industry, doing this to ourselves because all of the regulations and all the changes that came out of the CPB or you name the regulator For the most part always happening on the front side?
Speaker 4:So I think you are almost entirely correct.
Speaker 4:Right, you're mostly right, and so I think, if we all go back to what was the big thing, the big event that led to so many of the new rules that we have today you mentioned a couple of them the ATR rules and the TRID rules all came out of 2008, right, and what almost blew up? The whole thing? Right, worldwide, not even just in the United States. The only piece I would add to what you said so a lot happened on the origination side. You're right, because those loans that were then sold off and broken off into pieces to spread the risk around, that all started with the quality of the loan, or the lack thereof, of the mortgage that was originated in the first place. The only thing I would add, peter, to what you said is the servicing aspect of it came about because those loans that were originated wrongly to begin with, not with a borrower's ability to repay everybody was getting a loan, whether really they could afford it or not. That led to higher rates of default, right, and that's really what was the impetus that caused the blow up that led to this. So you're right, while that started from the quality of how the loans originated in the first place. One of the responses to it, in addition to ATR and the ability to repay and TRID, was also the servicing rules that amended both TILA and RESPA that the CFPB did and then continues to enforce and may continue to enforce someday in some form. So the result of it led to these servicing rules, which are now so much more, so much more detailed. And just to hit again on what Mandy was saying to you in the last one, even for a loan, that's on what I call the happy path the borrower's paying, they're not in default. There's all kinds of things that a servicer still needs to comply with, such as are you applying payments proper, right? And what about if there is an escrow account for taxes and insurance? Are you doing the analysis you need to do every year? Are the premiums and the property taxes actually being paid? I see problems in those areas all the time and I think, peter, that's a good lead in.
Speaker 4:To get back into your last question, which are? What are some of the top areas? Maybe a top three, a top five areas of most concern? So I'll start with ones that are on the happy path, and there's a couple there. I just hit on one, which is escrow administration, and so that is four accounts where there might be an escrow account set up for the payment of property taxes and insurance. Number one companies need to be analyzing those loans on an annual basis, figuring out if there might be a shortage, right. So, for example, premiums change, the property can be reassessed, the amount that's needed for property taxes can change, so there could be either a shortage of funds in the member's escrow account or a surplus of funds in the member's escrow account.
Speaker 4:Either way, there are action steps that a servicer needs to take. I can tell you, peter, from the credit unions that I've talked to that I've worked with. The level of knowledge related to that part of it ranges from credit unions who are on top of it to credit unions that couldn't even produce a report of all of their loans that have an escrow account to determine which ones needed to be analyzed. So that's a huge issue, and those are not borrowers that are in default, right. So another example would be something else that you hit on, which is customer service. If a borrower calls in, if they have a question, they make a request. There are rules, not just from an NCUA perspective but, for example, any agencies. If a credit union's making loans, that might be Fannie Mae or Freddie Mac loans, there are requirements for when calls need to be answered right and what's the pickup rate or does a call get abandoned. So even for loans where the borrower is paying, there are lots of elements where a servicer needs to comply and again you need people and resources and systems and reporting enabled to do all of that correctly for all of your loans. The more loans you have, the harder that can be, especially without good, strong processes and procedures. Now a couple more specifics for you for loans that maybe fall off the happy path and they go into default.
Speaker 4:The first big area and if I were to tell you the number one thing, whether it's NCUA or when it was the CFPB or any other agency, anyone doing an exam is loss mitigation, and that process starts from the very moment a borrower might turn in an application or part of an application, because what happens a lot is they don't give you everything and so that application for loss is incomplete. Well, what's the process of acknowledging that by the servicer to the member? Telling the member what's needed to get that application complete, giving them a time frame to do it and what are your follow ups with that member to get that incomplete application complete? Once you get that complete application, the process for reviewing that member for whatever loss options might be available, making that decision and the timing of it.
Speaker 4:And then another area is fees. So if I had to say what's the fifth one, it would be fees, and that would be whether fees are charged at all. Should they have been so, for example, some of the things that I've seen and that auditors hit on a lot is that a fee is charged for a particular service, but that service wasn't actually performed. So you might be asking how might that happen? Well, an example of that could be a property preservation type fee, and a lot of those fees get charged like every 30 days or every 60 days automatically in a servicer system, which is something that's designed to be helpful, right, so that all borrowers have the same thing happen. But if no one actually went out and looked at the property, then that fee ought not to have been assessed. Secondly, there could be fees such as a late fee or an NSF fee, and those fees often get waived.
Speaker 4:But the question is, do servicers have consistent processes for doing that, or might one borrower call ask to get the fee waived? The rep waives it right over the phone. The next borrower calls and they're told no, we can't do that for you, right? Same company, two different results. And then, just to put a bow on all of this for you, peter, imagine, in all of these areas where there might be discretion, if borrowers who get a good result, like a fee waive for example, happen to be, let's say, a white male, right, non-Hispanic, a majority borrower versus someone who maybe gets their request denied and they happen to be a member of a minority.
Speaker 4:That brings up potential fair servicing issues. And if I were to tell you another area where companies, credit unions, are telling me, is that even a thing? Fair servicing would be at the very top of the list of people asking me is that a thing? It's just like where you started this question, peter, which is isn't most of this coming on the origination side? A lot of folks credit unions and elsewhere know what fair lending is right the approval, denial of the application, the price. A lot of people don't know even that fair servicing is a thing, or how to do it or what you're supposed to do once you know that it is a thing.
Speaker 2:OK, it's interesting and I love the fact that you brought the fees. I mean, that's been in the spotlight a lot recently. Okay, so NCUA CFPB have been coming in and doing a lot of aud. It that our listeners really need to pay attention to and make sure that they are not doing or correcting as soon as possible so they're not getting findings.
Speaker 4:Excellent question and, just at the outset, what I would add to it is despite what's been going on, for example, at the CFPB or maybe at other agencies, all of the laws and regs that servicers need to comply with are still there. They're still on the books, right? They haven't been repealed, and so, whether someone comes out and audits you right now or not, or might it be a year or a couple of years down the road, they will be looking back right. So there's no, in other words, waiting or not complying right now because no one might be coming to your door right now. That's not a thing, Right, and it ought not be a thing for a servicer, because eventually you will get audited and they will be looking back at what you've done since the last time they came in or before.
Speaker 4:Now to your point what are examiners find? Now to your point what are examiners finding? I will start with the place where examiners start, and that's with a credit union's policies and procedures. So, number one do you have them? Do you have them for all aspects related to your servicing operations? Are they sufficient to know that if your employees followed your policies and procedures, would they then be servicing loans compliantly and, even beyond that, giving those members a good experience for that up to 30-year period where you're servicing their loan. And so one thing that examiners find all the time is that there is not sufficient policies, procedures, infrastructure. Peter, you hit on quality control and actually having a process of reviewing loans on a monthly and quarterly basis and coming up with reports that say either there's no issues or we did find some issues right. This last minute application wasn't considered or it wasn't considered timely, just as an example and are there action steps that get taken by the servicer based on the results of those audits? So the lack of a sufficient QC program is another finding that's very common. A third one is the one you and I were just discussing, and that's fees Either the assessment of fees when they ought not to have been assessed and or the waiving of fees in a manner that's not consistent among members or among borrowers.
Speaker 4:And I would go and that's also a good segue back to policies and procedures. In addition to maybe not having enough or they're not being sufficient, the other thing that the NCUA or other auditors will do is they will say fine, these are your policies and procedures, this is what you say you do. Now I, the auditor, am going to look at, to start with, a small sample of your loans. Why are they doing that? Because they want to know are you in actual practice, are you doing what your policies and procedures say you do? Or, if you are, are you doing them all the time or only some of the time?
Speaker 4:And so that's something that's found very commonly, that your policies and procedures say X and what actually is happening at the credit union, either some of the time or more than some of the time, is Y, and obviously X doesn't equal Y and that's a problem, right? So, lastly, I'd hit on loss mitigation we touched on that as well, Actually the applications, getting them from complete to complete, as well as the decision and our different borrowers, who are similar, getting similar decisions or are they being treated differently. So that's really about a good five areas of the most common findings, not only that I see from audits and examinations, but that I see when working with credit unions.
Speaker 2:Yeah, I love that you brought up. You know policies, procedures. You know throwing processes in there and having them documented. You know a long, long time ago, you know throwing processes in there and having them documented. You know long, long time ago, you know, I was in change management. That was really my job to sit down and document. You know everyone's roles and responsibilities, type them up and make sure everything was properly documented. And what I found was you know that was oftentimes a saving grace during any audit be able to produce those documents and show them. Hey, this is our procedure, this is how we do it and it matches up to our policy. Right, as long as we show them that they didn't question anything. Right?
Speaker 4:The conversation stopper. Right, which is my favorite thing. You don't want conversation starters, you want conversation stoppers.
Speaker 2:Yeah, it's like they didn't even bother, like we use. An easy example is TRID Right, I was at it was as unfortunate as at a community bank. At that time they came in and do a TRID audit. They want to see our TRID policy and procedures, fully expecting us not to have it. Thankfully, I was brought in to to to write all of them, so I did, and it was the fastest audit that the FDIC ever did at a community bank because they, I showed them, passed and they were out. They looked at two loans. The two loans passed. We were good, right, and so I love that you said that, because it was always one of the things that saved my bacon, because I always had those ready.
Speaker 4:Such a success story, right To think about where the bank was before you got there and what that exam would have been like if you hadn't been there and done it Right, it's easy just to document and they don't be pretty.
Speaker 2:Yeah, you can literally just be bullet points, step one, step two, step three, and as long as it matches up to your policy of things that you're supposed to be doing, you're good.
Speaker 4:Right, that's right. It's two steps. Right. You got to document it and then make sure your process actually matches it.
Speaker 2:That's right. Two steps, yeah, that's exactly it. Well, scott, we gotta start transitioning. But before we do last question, like I said, first question always the same, last question is always the same. Last question is actually no. Before I ask this last question, I do want to ask you one more question. Yeah, do you have any final thoughts on servicing compliance for credit unions and things that they can do to really make sure that they're staying ahead, or anything in general? Because I mean, again, this is a new frontier for Acuma. Our credit unions are really starting to be really hungry for this type of content. I we want to be better, so any final thoughts on this whole conversation?
Speaker 4:Absolutely. I'd say two things. Number one, so two words to understand and to look. So by understand I mean, again, I think a lot of people know things like trade and ability to repay, but to understand all of the different requirements on the servicing side, from the time that loan is boarded until the time it's resolved, hopefully with a payoff and not a foreclosure or something like that. So understand what all the obligations are for you servicing loans or, if you use a sub, what they're supposed to be doing and, again, areas where I'm happy to help answer questions and bounce ideas off with folks.
Speaker 4:That's number one. Understand. Number two is look, meaning to look at your operations, from your policies and procedures first, then to your actual processes, to see if it matches and by doing that, to look at loans as well and to see, at the end of the day, how are we doing so that you're not in this place where I mentioned earlier that you least want to be, which is unknowable risk. Knowable risk if you know it, that's fine, because you can put in an action plan to correct it, and then that risk becomes no risk. If you don't know what your risk is, then, among other things, peter, it's a constant state of anxiety, right. So understand and look.
Speaker 2:Okay, love it All. Right, real last question. Yeah, it kind of connects back to the first question, but what keeps you going? What keeps you ticking? You're just like everyone else. We take one foot out of bed every single morning and then we just keep pushing forward. What keeps you going?
Speaker 4:I will tell you. I think if I would say that in one word, it would be passion. I am passionate about compliance. I always have been, and now for the last five and a half years where it's been not just at one company but helping many, peter, I am passionate about helping companies comply. One of the reasons for that is because, if a company does, if all the credit unions listening to us today a compliant infrastructure and culture will help save money and help make money. Why do I say that? Because you'll save money with fines and all kinds of reputational damage, lawsuits, refunds, all of those different things. But you'll also, in addition to saving money, you'll make money because your borrowers, your members, are going to have a great experience and they're going to refer friends and family to you because they want them to have the same great experience that you had. So people don't usually think of compliance this way, but you can both save and make money while being more compliant at the same time. That's my passion, peter. That's what I set out to do every day.
Speaker 2:I love it. Great answer, great answer. All right, scott, let's transition to the second segment of the podcast and again in the compliance miniseries, we are going to do the most requested, fan favorite segment of dad jokes. So prior to the recording, I asked you to come prepared with two dad jokes. So here's what we're going to do You're going to do your two dad jokes, justin is going to do his two dad jokes and I will wrap up with my two dad jokes. Sound good?
Speaker 4:I love it. So I'm first in this in the extravaganza of dad jokes.
Speaker 2:You most certainly are so.
Speaker 4:I did my homework. Peter, I tell you I like the second one even more than the first, so I'm going to warm you up with the first one and then give you the second one. So the first one is why did the banana go to the doctor? He had a splitting headache. Not bad, that's a great guess.
Speaker 4:The actual answer is because he wasn't peeling well, so that was just the warm-up, peter. Okay, dad. Joke number two Did you know, peter and Justin and Krista? Did you know that the first original French fries were not in fact made in France? They were made in Greece, you're welcome, that's good, thank you I like that one. I like that one. That's one of my favorites.
Speaker 5:That's good, all right, justin.
Speaker 4:All right, Justin.
Speaker 5:All right, let's see if I can top those. What did one wall say to the other wall? You don't know, I'll meet you at the corner.
Speaker 4:I'll accept that. I'll accept that alright.
Speaker 5:And then why do cows wear bells? Why, because their horns don't work.
Speaker 3:Why do cows wear?
Speaker 5:bells, why Because?
Speaker 4:their horns don't work, all right.
Speaker 2:All right, all right, got a few, okay. A horse walks into a bar. The bartender asks why the long face? The horse, not being able to comprehend human language, promptly shits on the floor and leaves no, okay sorry, I'm getting.
Speaker 4:It. Took me a second there you go.
Speaker 2:Thank you, I appreciate it uh, all right, here's my next one. Um, did you know that before crowbars were invented, crows mostly drink alone?
Speaker 4:I like that one okay, good, thank you.
Speaker 2:Apparently all mine flopped today, but thank you very much for laughing at that second one scott, you're welcome, I'll give this a redemption one um, why did a pig dressed in black never get bullied?
Speaker 5:I don't know.
Speaker 2:Why? Because Batman was sworn to protect Gotham.
Speaker 5:There you go. I like that one.
Speaker 2:All right. Well, scott, thank you very much for being such a great episode on this compliance, this Acumen On Point podcast, compliance mini episode of compliance miniseries. Truly enjoyed the conversation. And again thank you very much for being one of the moderators for our compliance miniseries, our servicing miniseries. Excuse me, but also again thank you to MQMR for being one of our acumen services providers. I truly appreciate everything that you and the rest of MQMR do for our members and the credit union industry.
Speaker 4:Absolutely our pleasure. Thanks so much, peter. I enjoyed it as well.
Speaker 2:Of course, and, justin, thank you very much.
Speaker 5:Thanks, Justin, Of course it was my pleasure.
Speaker 2:All right, and to quickly close out, thank you again to Consolidated Analytics for sponsoring today's episode and to all of you. We know your time is valuable. Thank you for tuning in to the latest episode of Acuna's On Point Podcast. We hope you enjoyed it. Until next time. Be well, my friends.
Speaker 1:Thanks for listening. We'll see you next time at the Acuma On Point podcast. If not already, be sure to subscribe and give us a five-star rating For more great episodes and information. Be sure to visit us online at acumaorg and to get the latest updates. Head over to our LinkedIn page.
