On August 7, 2019 Fannie Mae added further guidance to its Lender Post-Closing QC Review requirements. Specifically outlining the requirement for an independent audit of the Lenders QC process and procedures.

The lender must have an independent audit process to ensure the following:

  • Its post-closing QC process and procedures are followed by the QC staff.
  • Assessments and conclusions are recorded and consistently applied.
  • Findings must be accurately recorded and consistent with the defects noted in the lender’s system of record.

Results of the QC audit must be distributed to senior management. The audit results must include an affirmative statement that no influence from other business units or bias in the QC conclusions was apparent. Management must distribute the results to the appropriate areas within the organization and an action plan must be established for remediation or changes to policies or processes, if appropriate. The lender must provide a copy of the QC audits and the audit of the QC process to Fannie Mae upon request.

Requirements related to QC independence must be incorporated into the lender’s QC plan and implemented by January 1, 2020.

If you have concerns about your Post-Closing QC, The Stonehill Group has you covered. Our deeply experienced team is ready to perform an independent audit, assist with a remediation plan, create a compliant QC plan or amend and update your existing QC Plan. Reach the pinnacle of compliance success with The StoneHill Group. We look forward to seeing you on the summit.


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