Customizing AllRegs Policies User Guide
Quick Start Steps
- Read the entire policy.
- Identify areas for revision.
- Discuss proposed changes and impacts with your in-house experts.
- Edit the policy to accurately describe your organization’s implementation of this policy.
- Find Help revising our MS Word policies at [insert link]
- Review changes with your team, get required approvals, accept the changes in the document and save your final version.
- Distribute the policy to everyone who needs to follow it!
Keep these points in mind
Your policy should:
- Be clear in what is required, whether the requirements are mandated by laws or regulations, or set by management or a board of directors.
- Reflect the way requirements are carried out in the organization. If you don’t do it, don’t say you do!
- Be reviewed and approved by upper management or the board of directors, and approved again at periodic intervals.
You may need to insert references to supporting job aids or develop other instructional materials to explain workflows or step-by-step actions, such as how to use related software. Those are procedural steps that don’t need board approval. Procedural steps are documented outside the policy manual and help your staff adhere to policy.
Things to consider as you develop a policy
Structure & Analysis
- How does this policy impact various departments?
- Does this policy affect branches differently?
- What procedures need to be documented or developed to comply with this policy?
- Does your organization have the tools or systems in place to monitor this policy effectively?
- How will this policy affect your business partners?
- Is the policy for internal or external use?
- How will enforcement of the policy be carried out internally?
- Which business units are impacted by this policy?
- Which key staff members need this written policy?
- How will this policy be distributed? Printed, website, centralized network location, training department?
- What training is needed to implement this policy?
- How will coordination of distribution and training be managed?
- Will the implementation of this policy impact systems or databases?
- Can your organization’s systems accommodate this policy?
- Does the implementation of this policy require IT resources, system modifications, or testing?
Monitoring / Auditing
- Can this policy be audited or monitored via system reporting, edit checks or manually?
- Should this policy be included in a Quality Control review?
- What are the repercussions of not complying with this policy or varying from established procedures?
- Who will perform the monitoring and testing of this policy or procedure?
- Does your organization have the resources to perform any required monitoring or auditing internally?
- What positions or departments will receive reports of the monitoring/auditing results? Board, C-level managers, legal, compliance, risk management, ombudsman?
AllRegs policies are designed for all levels of financial institutions engaged in residential mortgage banking. The standards set out in our policies represent minimum requirements based on applicable legal and regulatory guidance and are intended to prevent violation of federal regulations related to mortgage lending and consumer compliance.
AllRegs Policy Manuals are “starter kits” for given topics. Technical writers and industry experts develop the manuals to provide a framework which addresses regulatory requirements, reflects industry best practice, and identifies areas for customization or refinement. AllRegs Policy Manuals are a valuable policy development tool for gaining focus and saving time. However, they are not a turnkey solution. Expect to invest time in the areas of procedural documentation, instructional relevance, corporate philosophy, monitoring, job aid, and related training.
Things to consider
- Each policy requires approval by Senior Management or the Board of Directors
- Monitoring of each policy is required. Include these policies in any procedures related to conducting annual audits.
- Designate a responsible party for overseeing maintenance of each policy.
- Closely monitor the individual record keeping requirements for each policy.