The Conference of State Bank Supervisors (CSBS) and the Multi-State Mortgage Committee (MMC) issued a report to state regulators regarding its 2015 review of the supervisory structure around examination and risk assessment of non-bank mortgage loan servicers. Notable servicing examination findings outlined in the report include: (i) violations and deficiencies related to loan transfer activity, noting that a “significant portion of servicing examination findings are tied to the mortgage servicing requirements implemented into the [RESPA] and [TILA] in January of 2014”; (ii) ineffective oversight of sub-servicer activity and insufficient third party vendor management; and (iii) ineffective examination management procedures on the part of mortgage servicers, leading to delayed examination processes, as well as impeded regulatory oversight. The report further outlines origination examination findings, emphasizing RESPA violations related to Mortgage Servicing Agreements (MSAs) which typically include payments for promotional advertising services performed on behalf of the mortgage company. According to the MMC, MSA-related violations carry high risk. Additional MMC 2015 observations outlined in the report include, but are not limited to, the following: (i) state license engagement of third party providers overseen by federal regulators resulted in an increase of state/federal communications and information sharing, fostering a stronger regulatory framework; (ii) lapses in loan originator education may lead to significant deficiencies at the company level; (iii) whistleblower information provided to the MMC in 2015 played a large role in uncovering prohibited activity; and (iv) technological systems with incorrect programming continue to cause lenders to charge borrowers statutorily prohibited fees. Finally, the report briefly touches on the CSBS’ and the NMLS’s Mortgage Call Report Analytics Tool – designed to provide detailed information about the loan portfolio and financial condition of a company – and the State Coordinating Committee’s coordinated efforts with the CFPB to include the development of the Coordinated Examination Guidance tool, which is intended to provide “suggested best practices for coordinated examinations and a step-by-step listing of action items to be completed during a coordinated examination.”