July 23, 2025 • 43 mins
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
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Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
The views and opinions expressed in this
podcast do not necessarilyreflect the views or positions
of Acuma, its board of directors, its management staff or its
members.
The podcast discussionpresented is conversational in
nature and for generalinformation only.
Speaker 2 (00:31):
Hello and welcome to Aqua's On Point Podcast, a
series focused on sharing thestories of people who are making
a positive impact in the creditunion mortgage industry.
I'm your host, Peter Benjamin.
Before we get to our episode,just a quick word from our
sponsor.
Speaker 3 (00:43):
This episode is brought to you by Consolidated
Analytics, helping credit unionsmake smarter mortgage decisions
, from origination to servicingand beyond, with expert
valuation, risk management andcompliance solutions.
They provide the insights youneed to protect your members and
grow your portfolio withconfidence.
Whether it's due diligence or acollateral risk assessment,
(01:04):
they help you navigate themarket with ease.
Learn more at due diligence ora collateral risk assessment.
They help you navigate themarket with ease.
Learn more atconsolidatedanalyticscom.
Speaker 2 (01:10):
Welcome to the fourth episode of our compliance
miniseries, where each episodewill feature an intimate
conversation with people who Iconsider to be experts in the
field and supporters of thecredit union movement.
As a reminder, with each ofthese episodes, it's our goal to
take a deep dive into variouscompliance topics that are
impacting and reshaping thecredit union mortgage industry.
(01:31):
Our next guest in thecompliance miniseries is Scott
Weintraub, Vice President ofCompliance with MQMR.
Scott, how are you doing today?
Speaker 4 (01:40):
I'm doing great, peter.
I'm so excited to be on withyou and Acuma, so thanks so much
for having me on.
Speaker 2 (01:45):
No, it's our pleasure .
We couldn't be more thrilled tohave you here One because we've
had the opportunity of gettingto know you through our
relationship with MQMR, havingMQMR be an AppGift service
provider.
You recently attended ourworkshop in Seattle.
You are one of our moderatorsfor our servicing network, so
(02:12):
we've gotten a chance to knowyou.
So we're really excited to sitdown with you and have this
conversation.
But before we really dive inand get to know you a bit more
and really talk, compliance, asalways, got to bring Justin in.
And here's the latest andgreatest happening over at Acuna
Hawk.
What's going on?
How are you doing today?
(02:33):
And please, please, tell uswhat is the latest greatest
happening over at Acuna.
I'm good, Peter.
Speaker 5 (02:37):
How are you Living the dream.
I love it, awesome.
So over here at Acuna, we aremid planning or not not even
planning we're mid getting readyto 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 eightweeks away now?
(03:00):
Roughly Right, something likethat.
Yeah, something like that.
So the speakers in the agendaare jam-packed with experts in
the mortgage industry.
I'm certain that if you come tothe event, it's going to be one
you don't want to miss, and ifyou aren't coming, then you're
going to be so sad becauseyou're going to miss the biggest
event for credit union mortgageprofessionals in the fall.
(03:21):
Registration's open, so headover to the ACME website and
come make your mark with us inDenver.
We can't wait to see you.
Aside from our annualconference, if you're looking
for additional networking andeducational opportunities, we
have our next network meeting,the Volume-Based Network.
They're going to have their Q3meeting in August, just a few
(03:42):
weeks away.
So information's already up onthe website.
So head over there and learnmore 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 (03:57):
All right, all right.
It's going to be awesome.
Can't wait for annual Annual isgoing 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 (04:10):
I mean, you've already said it this is probably
the best one that you puttogether in your time at Acumen.
I mean hands down.
Speaker 2 (04:17):
I mean, this is going to be something very, very,
very special.
Speaker 5 (04:21):
Yes, looking forward to it.
Speaker 2 (04:23):
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 verymuch.
No, scott, all right.
Turning over our sights back toyou.
You know, the actual employeepodcast is a people piece.
I mentioned that in my openingstatement.
You know I always say this.
I always go through the same,you know introduction, the first
(04:46):
question and the last questionis always the same.
You know, it's about divinginto who our speakers are,
getting to know them on a morepersonal level before we
actually really focus on themain topic.
And so the first question isalways you know who is Scott, or
who is the speaker?
(05:07):
Because I think that's the mostimportant thing about all of us
what makes us tick, what makesus who we are?
We're more than mortgageprofessionals.
We're more than the presidentof Mac.
We're more than the director ofmarketing for Actima.
We're more than everything.
So I think that's the mostimportant question.
I ask you all day today who isScott?
(05:28):
So do me a favor, walk usthrough that.
And then, of course, we'll diveinto our compliance miniseries.
So, first question who's Scott?
Speaker 4 (05:36):
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 thisindustry, I did not, from the
time I was a kid, say if only Icould grow up and work in
regulatory compliance in themortgage industry, right then
(05:56):
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 admitthat out loud.
But I spent most of mychildhood growing up in Southern
California, which is where Ilive now and I can't imagine
living anywhere else.
And then I went up to collegein the Bay Area and then out to
(06:18):
Washington DC for law school.
After law school I spent acouple of years at a law firm
and found very quickly that thatwasn't for me.
I liked the work, I didn't likethe environment and that law
firm didn't deal in mortgage atall.
It dealt mostly in healthinsurance and in defense and
(06:38):
didn't really lead to sleepingwell at night.
So, Peter, I saw an ad for ajob in-house with a mortgage
company and it said you neededtwo things.
One was three to five yearsexperience in reading laws and
interpreting them and knowinghow to comply with them.
Well, that I had.
Then, of course, it said youneeded three to five years
experience in the mortgageindustry, to which I said, well,
(07:00):
I have none, but maybewhoever's doing the hiring might
know that that part.
You could learn right what amortgage is and how that works,
and maybe I could convince themthat my learning curve would be
short.
Well, fortunately for me, that'sexactly what happened, and that
was back in 2003.
So now we're going on 22 yearswhere I've been in the mortgage
(07:22):
industry ever since and couldn'tbe happier about it exclusively
doing legal and regulatorycompliance.
So that involved working at afew different over the last 17
years before I got to MQMR a fewdifferent lenders and servicers
.
That included a servicer thatreally all they did was service
(07:44):
loans, and then some lenders whooriginated loans and either
service loans as well in-house,or had oversight and management
responsibilities over asubservicer who serviced the
loans for them.
So I've had a lot of experienceboth ways, with servicing
in-house and managing asubservicer who's doing the
day-to-day activities.
(08:05):
Then for the last five and ahalf 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, Allrelated to compliance, risk
management and audit, and so wehelp lenders, and particularly
(08:28):
servicers, with all aspects ofcompliance, of which, as you
know, Peter, there are so manythings, so many different
entities that could comeknocking on a credit union's
door, and so that's what we do,that's what my journey has been.
Speaker 2 (08:56):
I'm very confident that I'm at my last job.
We love helping companies, butin particular, I just like doing
things like this, which ishopefully passing on some
knowledge to your listeners.
The sharing of knowledge is oneof the things that makes the
credit union industry so special.
I think no matter who you talkto in our side, that's the first
thing they always say.
(09:17):
You know, credit union share,and the fact that that's
something that you thrive in,right of wanting to help,
(09:37):
wanting to really give back andshare the knowledge that you've
gained throughout all the years,that's absolutely amazing.
I mean, I sensed it when wewere in Seattle and you really
embraced everyone in that roomand all you wanted to do is, one
, listen, but two, really helpthem learn and kind of flourish.
(10:02):
I think it's awesome.
So us, us kind of asking youand your, your willingness to
kind of jump in and helpfacilitate again, you know that
that servicing network that wehave it's just only exhibits
your desire to help.
So so, scott, let's, let's,let's pivot and kind of talk
(10:25):
about, you know, here we are inthe compliance miniseries and
last year we did the, the MIminiseries, where we really
focus on, you know, theimportance of MI and kind of
debunking the myth.
This year we decided to go withcompliance because it ended up
being more timely than we everthought.
We picked compliance becauseit's it's one, it's always been
(10:47):
a moving target, but two, itjust happened to be even more of
a moving target this year thanwe ever thought it would be.
But servicing, historicallyspeaking, servicing has never
really been something thatAckman is focused on.
Yeah, we may have talked aboutit in passing, but servicing has
just only recently beensomething that our members have
really started focusing on.
(11:07):
And you know, prior to thisrecording, you and I really
started having a conversation asto why allocations when it
comes to complianceprofessionals within credit
unions, who, and really theinvestment of compliance
(11:32):
professionals on the servicingside, 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 agreat conversation we're going
to have, so let's start withthat.
So what are your thoughts onjust you know, credit unions
allocating certain resources tocompliance on the servicing side
of the business?
Speaker 4 (11:53):
Excellent place to start, peter, and first I'd like
to hit on something that youmentioned, which is what I
noticed in both Seattle andSavannah, at both of the
workshops this year.
I think you're so right whenyou said that one of the things
that's unique about creditunions in that space is how much
they share, and I saw thatfirsthand, and if I could
contribute, if I contributed tothat conversation in any small
(12:14):
way, I'm happy to do it andcan't wait to do that even more.
Another way that credit unionsare unique similar a little bit
similar to banks, but certainlydifferent than a mortgage banker
that that's all they do is thatcredit unions, they don't just
make mortgages.
It's certainly an importantpart of what they do, but it's
not the entirety of what they do.
(12:35):
And what I have found from somany conversations that I've had
with credit unions is thatbudgets are limited, and
particularly when it's relatedto compliance, which a lot of
companies don't necessarilythink that's where you make your
money in compliance, I wouldsuggest that it actually is, or
(12:55):
by saving money, you can helpyour company's bottom line, but
there isn't always enoughresources in terms of people,
dollars, systems, training, allof those different pieces to
that puzzle that helps youcreate a compliance
infrastructure.
What I found with credit unionsis, if there are resources that
(13:17):
are allocated to compliance, thelion's share of it goes to the
non-mortgage elements of whatthe credit union is doing.
Of it goes to the non-mortgageelements of what the credit
union is doing, much more so onthe depository side with those
accounts, versus specificallygoing to mortgage.
Further, when there isallocation done time, resources,
money, whatever that may berelated to compliance on the
(13:40):
mortgage side, it tends to bemore on the upfront side, on the
origination side, making theloan in the first place, as
opposed to servicing.
One of the reasons I havealways wondered about that is
because, as we all know, itcould take 30 days, 60 days,
right, maybe 90 days at theoutside to originate a loan for
(14:03):
a member.
The servicing relationshipcould last decades, right Up to
30 years.
And there are laws and when wesay laws, there are many of them
that a servicer would have tofollow for up to a period of
decades, right?
And yet, if there are resourcesallocated related to compliance
(14:24):
on the mortgage side, it tendsto be much more upfront and not
as much on the servicing side.
And so, peter, theconversations I have with credit
unions, I always start therewhat's allocated, either
internally or what vendors?
Might you have to help, or both?
And you're right, similar tohow Acuma maybe in the past,
before all the great things thatyou're doing now, wasn't as
(14:46):
focused on compliance on theservicing side.
That was true of the creditunions themselves as well, and I
think conversations that I'vehad with them have been very
eye-opening when they've thoughtabout some of these things.
Speaker 2 (14:59):
So it's interesting, right?
So, if you think about it, youhave some credit unions that
strictly portfolio and then youhave some credit unions that
sell some on the secondarymarket and they have some that
sell a whole bunch.
But let's focus on the two ofthem that I mentioned, the ones
that sell some and sell somethat sell a lot.
(15:20):
Typically, the ones that areselling on the secondary market
require some form of QC plan,sell a lot.
Typically, the ones that areselling on the secondary market
require some form of QC plan andthe QC plan does typically
require them to have some.
I know it's quality and notnecessary compliance, but it
typically requires you to havesome form of standards that you
must comply with, whether youare servicing retained or
(15:41):
servicing release, it doesn'treally matter.
You would think that they wouldinvest more resources into those
things, but I, I, I, from whatI'm seeing, it's still not the
case, right?
Like there's still very muchfalling short.
Technology is just isn't up topar or up to snuff.
Member service isn't still upto snuff, cause I think member
(16:07):
service does can very muchimpact compliance absolutely.
Uh and and now that you'resaying all these things, you're
right, you know, 30 year morelike we're.
You know we're blessed to havea 30-year mortgage.
You know, and with you know,three percent paper, there's a,
there's a fighting chance thatwe may have 30-year mortgages
(16:27):
that actually may mature for 30at 30 years right.
Speaker 4 (16:31):
Right Yep In the environment.
We're in now for sure.
Speaker 2 (16:33):
So you are, harm's right, I never actually really
sat down and thought about itthe compliance risk, on this
long-term effect of notinvesting in servicing and the
the servicing resources.
You're exposing yourself to alot of things If you only, we'll
(16:56):
say, front load your complianceresources 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 nextthing that we were going to
talk about.
It's really all the things thatyou have to focus on, right?
(17:18):
So if you were to list, likethey'll say, the top five, the
top five rules, regs, acts, youname it that could potentially
expose a credit union topotential harm and let's not
even focus on things that anNCOA or CPV auditor is going to
come and look at, but let's saythat the fundamental top five,
(17:42):
what are they?
Speaker 4 (17:43):
Yeah, absolutely, and I think, right before I get
into that, I would just say as ageneral manner, you hit on a
couple of things that are reallyimportant, which is there is a
ton of legal and compliance riskand exposure if a company is
not focused on it and doesn'thave this infrastructure in
place of compliance and youmentioned QC, that's an
(18:05):
important part of it and it doesget to compliance aspects, and
I'm going to give some of theexamples when I talk about this
top five.
And if you don't have a processor a system to look at some of
your loans, then you're in thatplace that I think Peter, you
and I talked about right beforewe jumped on in the recording,
which is you're in what Iconsider to be the worst
(18:26):
possible place, which isunknowable risk.
If you're not looking, then youdon't know where you might have
a gap or a hole, and that'sgoing to put you in a situation
where a regulator someday isgoing to tell you where your
gaps and your holes are, andthen you have two problems One,
the gap or the hole itself, andsecondly, they will say your
(18:48):
compliance infrastructure wasnot sufficient enough to have
found these yourself, and so youhave a general problem in
addition to the specific ones,so so, so it's already, you know
, is this?
Speaker 2 (19:04):
I'm not.
I guess I'm pausing because I'mtrying to think of a way to
kind of frame this up.
Yeah, is this all a result ofthe fact that a lot of the big
(19:27):
rules or changes that ourindustry has gone through in
recent time has all been on thefront end?
You know, let's think about it.
You know, atrqm Yep Trade Tradeon the front end.
You know, let's think about it.
You know atrqm yep trade trade.
Um, I guess humda, for the mostpart, 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 themajor changes happened on the
(19:53):
consumer-facing side?
Although, yes, servicing doeshave a consumer-facing component
to it, actually a majorcomponent, but that's only when
there's a need, right.
People often forget and in ourlast episode of the Compliance
(20:16):
Miniseries, mandy Phillips withASUS Quality Management
mentioned very eloquently thatpeople often forget that just
because you are not late or indefault doesn't mean you can't
call or should not call yourservicer, right?
And so that's why people oftenforget that, hey, I just need to
(20:39):
call.
I need to call and have thatinteraction, get things updated,
et cetera, et cetera, et cetera.
I digress to my conversation.
My question is are we, as anindustry, doing this to
ourselves because all of theregulations and all the changes
that came out of the CPB or youname the regulator For the most
(21:00):
part always happening on thefront side?
Speaker 4 (21:03):
So I think you are almost entirely correct.
Right, you're mostly right, andso I think, if we all go back to
what was the big thing, the bigevent that led to so many of
the new rules that we have todayyou mentioned a couple of them
the ATR rules and the TRID rulesall came out of 2008, right,
and what almost blew up?
(21:24):
The whole thing?
Right, worldwide, not even justin the United States.
The only piece I would add towhat you said so a lot happened
on the origination side.
You're right, because thoseloans that were then sold off
and broken off into pieces tospread the risk around, that all
started with the quality of theloan, or the lack thereof, of
(21:45):
the mortgage that was originatedin the first place.
The only thing I would add,peter, to what you said is the
servicing aspect of it cameabout because those loans that
were originated wrongly to beginwith, not with a borrower's
ability to repay everybody wasgetting a loan, whether really
they could afford it or not.
That led to higher rates ofdefault, right, and that's
(22:07):
really what was the impetus thatcaused the blow up that led to
this.
So you're right, while thatstarted from the quality of how
the loans originated in thefirst place.
One of the responses to it, inaddition to ATR and the ability
to repay and TRID, was also theservicing rules that amended
(22:28):
both TILA and RESPA that theCFPB did and then continues to
enforce and may continue toenforce someday in some form.
So the result of it led tothese servicing rules, which are
now so much more, so much moredetailed.
And just to hit again on whatMandy was saying to you in the
(22:49):
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 thingsthat a servicer still needs to
comply with, such as are youapplying payments proper, right?
And what about if there is anescrow account for taxes and
insurance?
Are you doing the analysis youneed to do every year?
(23:10):
Are the premiums and theproperty taxes actually being
paid?
I see problems in those areasall the time and I think, peter,
that's a good lead in.
To get back into your lastquestion, which are?
What are some of the top areas?
Maybe a top three, a top fiveareas of most concern?
So I'll start with ones thatare on the happy path, and
(23:34):
there's a couple there.
I just hit on one, which isescrow administration, and so
that is four accounts wherethere might be an escrow account
set up for the payment ofproperty taxes and insurance.
Number one companies need to beanalyzing those loans on an
annual basis, figuring out ifthere might be a shortage, right
(23:57):
.
So, for example, premiumschange, the property can be
reassessed, the amount that'sneeded for property taxes can
change, so there could be eithera shortage of funds in the
member's escrow account or asurplus of funds in the member's
escrow account.
Either way, there are actionsteps that a servicer needs to
take.
(24:17):
I can tell you, peter, from thecredit unions that I've talked
to that I've worked with.
The level of knowledge relatedto that part of it ranges from
credit unions who are on top ofit to credit unions that
couldn't even produce a reportof all of their loans that have
an escrow account to determinewhich ones needed to be analyzed
(24:39):
.
So that's a huge issue, andthose are not borrowers that are
in default, right.
So another example would besomething else that you hit on,
which is customer service.
If a borrower calls in, if theyhave a question, they make a
request.
There are rules, not just froman NCUA perspective but, for
(25:00):
example, any agencies.
If a credit union's makingloans, that might be Fannie Mae
or Freddie Mac loans, there arerequirements for when calls need
to be answered right and what'sthe pickup rate or does a call
get abandoned.
So even for loans where theborrower is paying, there are
lots of elements where aservicer needs to comply and
(25:22):
again you need people andresources and systems and
reporting enabled to do all ofthat correctly for all of your
loans.
The more loans you have, theharder that can be, especially
without good, strong processesand procedures.
Now a couple more specifics foryou for loans that maybe fall
off the happy path and they gointo default.
(25:43):
The first big area and if I wereto tell you the number one
thing, whether it's NCUA or whenit was the CFPB or any other
agency, anyone doing an exam isloss mitigation, and that
process starts from the verymoment a borrower might turn in
an application or part of anapplication, because what
happens a lot is they don't giveyou everything and so that
(26:07):
application for loss isincomplete.
Well, what's the process ofacknowledging that by the
servicer to the member?
Telling the member what'sneeded to get that application
complete, giving them a timeframe to do it and what are your
follow ups with that member toget that incomplete application
complete?
Once you get that completeapplication, the process for
(26:29):
reviewing that member forwhatever loss options might be
available, making that decisionand the timing of it.
And then another area is fees.
So if I had to say what's thefifth one, it would be fees, and
that would be whether fees arecharged at all.
Should they have been so, forexample, some of the things that
(26:50):
I've seen and that auditors hiton a lot is that a fee is
charged for a particular service, but that service wasn't
actually performed.
So you might be asking howmight that happen?
Well, an example of that couldbe a property preservation type
fee, and a lot of those fees getcharged like every 30 days or
every 60 days automatically in aservicer system, which is
(27:14):
something that's designed to behelpful, right, so that all
borrowers have the same thinghappen.
But if no one actually went outand looked at the property,
then that fee ought not to havebeen assessed.
Secondly, there could be feessuch as a late fee or an NSF fee
, and those fees often getwaived.
But the question is, doservicers have consistent
(27:36):
processes for doing that, ormight one borrower call ask to
get the fee waived?
The rep waives it right overthe phone.
The next borrower calls andthey're told no, we can't do
that for you, right?
Same company, two differentresults.
And then, just to put a bow onall of this for you, peter,
imagine, in all of these areaswhere there might be discretion,
if borrowers who get a goodresult, like a fee waive for
(28:00):
example, happen to be, let's say, a white male, right,
non-Hispanic, a majorityborrower versus someone who
maybe gets their request deniedand they happen to be a member
of a minority.
That brings up potential fairservicing issues.
And if I were to tell youanother area where companies,
credit unions, are telling me,is that even a thing?
(28:21):
Fair servicing would be at thevery top of the list of people
asking me is that a thing?
It's just like where youstarted this question, peter,
which is isn't most of thiscoming on the origination side?
A lot of folks credit unionsand elsewhere know what fair
lending is right the approval,denial of the application, the
(28:42):
price.
A lot of people don't know eventhat fair servicing is a thing,
or how to do it or what you'resupposed to do once you know
that it is a thing.
Speaker 2 (28:53):
OK, it's interesting and I love the fact that you
brought the fees.
I mean, that's been in thespotlight a lot recently.
Okay, so NCUA CFPB have beencoming in and doing a lot of aud
(29:14):
.
It that our listeners reallyneed to pay attention to and
(29:38):
make sure that they are notdoing or correcting as soon as
possible so they're not gettingfindings.
Speaker 4 (29:44):
Excellent question and, just at the outset, what I
would add to it is despitewhat's been going on, for
example, at the CFPB or maybe atother agencies, all of the laws
and regs that servicers need tocomply with are still there.
They're still on the books,right?
They haven't been repealed, andso, whether someone comes out
(30:04):
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 becoming to your door right now.
That's not a thing, Right, andit ought not be a thing for a
servicer, because eventually youwill get audited and they will
(30:26):
be looking back at what you'vedone since the last time they
came in or before.
Now to your point what areexaminers find?
Now to your point what areexaminers finding?
I will start with the placewhere examiners start, and
that's with a credit union'spolicies and procedures.
So, number one do you have them?
Do you have them for allaspects related to your
(30:48):
servicing operations?
Are they sufficient to knowthat if your employees followed
your policies and procedures,would they then be servicing
loans compliantly and, evenbeyond that, giving those
members a good experience forthat up to 30-year period where
you're servicing their loan.
And so one thing that examinersfind all the time is that there
(31:13):
is not sufficient policies,procedures, infrastructure.
Peter, you hit on qualitycontrol and actually having a
process of reviewing loans on amonthly and quarterly basis and
coming up with reports that sayeither there's no issues or we
did find some issues right.
This last minute applicationwasn't considered or it wasn't
(31:35):
considered timely, just as anexample and are there action
steps that get taken by theservicer based on the results of
those audits?
So the lack of a sufficient QCprogram is another finding
that's very common.
A third one is the one you andI were just discussing, and
that's fees Either theassessment of fees when they
(31:56):
ought not to have been assessedand or the waiving of fees in a
manner that's not consistentamong members or among borrowers
.
And I would go and that's also agood segue back to policies and
procedures.
In addition to maybe not havingenough or they're not being
sufficient, the other thing thatthe NCUA or other auditors will
(32:18):
do is they will say fine, theseare your policies and
procedures, this is what you sayyou do.
Now I, the auditor, am going tolook at, to start with, a small
sample of your loans.
Why are they doing that?
Because they want to know areyou in actual practice, are you
doing what your policies andprocedures say you do?
(32:40):
Or, if you are, are you doingthem all the time or only some
of the time?
And so that's something that'sfound very commonly, that your
policies and procedures say Xand what actually is happening
at the credit union, either someof the time or more than some
of the time, is Y, and obviouslyX doesn't equal Y and that's a
(33:03):
problem, right?
So, lastly, I'd hit on lossmitigation we touched on that as
well, Actually the applications, getting them from complete to
complete, as well as thedecision and our different
borrowers, who are similar,getting similar decisions or are
they being treated differently.
So that's really about a goodfive areas of the most common
(33:24):
findings, not only that I seefrom audits and examinations,
but that I see when working withcredit unions.
Speaker 2 (33:30):
Yeah, I love that you brought up.
You know policies, procedures.
You know throwing processes inthere 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 sitdown and document.
You know everyone's roles andresponsibilities, type them up
(33:51):
and make sure everything wasproperly documented.
And what I found was you knowthat was oftentimes a saving
grace during any audit be ableto 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 themthat they didn't question
(34:17):
anything.
Right?
Speaker 4 (34:18):
The conversation stopper.
Right, which is my favoritething.
You don't want conversationstarters, you want conversation
stoppers.
Speaker 2 (34:24):
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 anddo a TRID audit.
They want to see our TRIDpolicy and procedures, fully
expecting us not to have it.
Thankfully, I was brought in toto to write all of them, so I
(34:47):
did, and it was the fastestaudit that the FDIC ever did at
a community bank because they, Ishowed them, passed and they
were out.
They looked at two loans.
The two loans passed.
We were good, right, and so Ilove that you said that, because
it was always one of the thingsthat saved my bacon, because I
(35:08):
always had those ready.
Speaker 4 (35:11):
Such a success story, right To think about where the
bank was before you got thereand what that exam would have
been like if you hadn't beenthere and done it Right, it's
easy just to document and theydon't be pretty.
Speaker 2 (35:25):
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 thatyou're supposed to be doing,
you're good.
Speaker 4 (35:33):
Right, that's right.
It's two steps.
Right.
You got to document it and thenmake sure your process actually
matches it.
Speaker 2 (35:40):
That's right.
Two steps, yeah, that's exactlyit.
Well, scott, we gotta starttransitioning.
But before we do last question,like I said, first question
always the same, last questionis 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 finalthoughts on servicing compliance
for credit unions and thingsthat they can do to really make
(36:03):
sure that they're staying ahead,or anything in general?
Because I mean, again, this isa new frontier for Acuma.
Our credit unions are reallystarting to be really hungry for
this type of content.
I we want to be better, so anyfinal thoughts on this whole
(36:28):
conversation?
Speaker 4 (36:29):
Absolutely.
I'd say two things.
Number one, so two words tounderstand and to look.
So by understand I mean, again,I think a lot of people know
things like trade and ability torepay, but to understand all of
the different requirements onthe servicing side, from the
time that loan is boarded untilthe time it's resolved,
(36:51):
hopefully with a payoff and nota foreclosure or something like
that.
So understand what all theobligations are for you
servicing loans or, if you use asub, what they're supposed to
be doing and, again, areas whereI'm happy to help answer
questions and bounce ideas offwith folks.
That's number one.
Understand.
Number two is look, meaning tolook at your operations, from
(37:14):
your policies and proceduresfirst, then to your actual
processes, to see if it matchesand by doing that, to look at
loans as well and to see, at theend of the day, how are we
doing so that you're not in thisplace 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
(37:37):
in an action plan to correct it, and then that risk becomes no
risk.
If you don't know what yourrisk is, then, among other
things, peter, it's a constantstate of anxiety, right.
So understand and look.
Speaker 2 (37:51):
Okay, love it All.
Right, real last question.
Yeah, it kind of connects backto the first question, but what
keeps you going?
What keeps you ticking?
You're just like everyone else.
We take one foot out of bedevery single morning and then we
just keep pushing forward.
What keeps you going?
Speaker 4 (38:07):
I will tell you.
I think if I would say that inone word, it would be passion.
I am passionate aboutcompliance.
I always have been, and now forthe last five and a half years
where it's been not just at onecompany but helping many, peter,
I am passionate about helpingcompanies comply.
One of the reasons for that isbecause, if a company does, if
(38:29):
all the credit unions listeningto us today a compliant
infrastructure and culture willhelp save money and help make
money.
Why do I say that?
Because you'll save money withfines and all kinds of
reputational damage, lawsuits,refunds, all of those different
things.
But you'll also, in addition tosaving money, you'll make money
because your borrowers, yourmembers, are going to have a
(38:51):
great experience and they'regoing to refer friends and
family to you because they wantthem to have the same great
experience that you had.
So people don't usually thinkof compliance this way, but you
can both save and make moneywhile being more compliant at
the same time.
That's my passion, peter.
That's what I set out to doevery day.
Speaker 2 (39:11):
I love it.
Great answer, great answer.
All right, scott, let'stransition to the second segment
of the podcast and again in thecompliance miniseries, we are
going to do the most requested,fan favorite segment of dad
jokes.
So prior to the recording, Iasked you to come prepared with
two dad jokes.
So here's what we're going todo You're going to do your two
dad jokes, justin is going to dohis two dad jokes and I will
(39:34):
wrap up with my two dad jokes.
Sound good?
Speaker 4 (39:37):
I love it.
So I'm first in this in theextravaganza of dad jokes.
Speaker 2 (39:40):
You most certainly are so.
Speaker 4 (39:43):
I did my homework.
Peter, I tell you I like thesecond one even more than the
first, so I'm going to warm youup with the first one and then
give you the second one.
So the first one is why did thebanana go to the doctor?
He had a splitting headache.
Not bad, that's a great guess.
(40:07):
The actual answer is because hewasn'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 firstoriginal French fries were not
in fact made in France?
(40:28):
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 (40:46):
That's good, all right, justin.
Speaker 4 (40:48):
All right, Justin.
Speaker 5 (40:49):
All right, let's see if I can top those.
What did one wall say to theother wall?
You don't know, I'll meet youat the corner.
Speaker 4 (41:08):
I'll accept that.
I'll accept that alright.
Speaker 5 (41:11):
And then why do cows wear bells?
Why, because their horns don'twork.
Speaker 3 (41:16):
Why do cows wear?
Speaker 5 (41:17):
bells, why Because?
Speaker 4 (41:19):
their horns don't work, all right.
Speaker 2 (41:22):
All right, all right, got a few, okay.
A horse walks into a bar.
The bartender asks why the longface?
The horse, not being able tocomprehend human language,
promptly shits on the floor andleaves no, okay sorry, I'm
(41:47):
getting.
Speaker 4 (41:47):
It.
Took me a second there you go.
Speaker 2 (41:48):
Thank you, I appreciate it uh, all right,
here's my next one.
Um, did you know that beforecrowbars were invented, crows
mostly drink alone?
Speaker 4 (42:01):
I like that one okay, good, thank you.
Speaker 2 (42:03):
Apparently all mine flopped today, but thank you
very much for laughing at thatsecond one scott, you're welcome
, I'll give this a redemptionone um, why did a pig dressed in
black never get bullied?
Speaker 5 (42:21):
I don't know.
Speaker 2 (42:21):
Why?
Because Batman was sworn toprotect Gotham.
Speaker 5 (42:27):
There you go.
I like that one.
Speaker 2 (42:31):
All right.
Well, scott, thank you verymuch for being such a great
episode on this compliance, thisAcumen On Point podcast,
compliance mini episode ofcompliance miniseries.
Truly enjoyed the conversation.
And again thank you very muchfor being one of the moderators
for our compliance miniseries,our servicing miniseries.
(42:52):
Excuse me, but also again thankyou to MQMR for being one of
our acumen services providers.
I truly appreciate everythingthat you and the rest of MQMR do
for our members and the creditunion industry.
Speaker 4 (43:08):
Absolutely our pleasure.
Thanks so much, peter.
I enjoyed it as well.
Speaker 2 (43:11):
Of course, and, justin, thank you very much.
Speaker 5 (43:14):
Thanks, Justin, Of course it was my pleasure.
Speaker 2 (43:16):
All right, and to quickly close out, thank you
again to Consolidated Analyticsfor sponsoring today's episode
and to all of you.
We know your time is valuable.
Thank you for tuning in to thelatest episode of Acuna's On
Point Podcast.
We hope you enjoyed it.
Until next time.
Be well, my friends.
Speaker 1 (43:30):
Thanks for listening.
We'll see you next time at theAcuma On Point podcast.
If not already, be sure tosubscribe and give us a
five-star rating For more greatepisodes and information.
Be sure to visit us online atacumaorg and to get the latest
updates.
Head over to our LinkedIn page.
The views and opinions expressed in this
podcast do not necessarilyreflect the views or positions
of Acuma, its board of directors, its management staff or its
members.
The podcast discussionpresented is conversational in
nature and for generalinformation only.
Speaker 2 (00:31):
Hello and welcome to Aqua's On Point Podcast, a
series focused on sharing thestories of people who are making
a positive impact in the creditunion mortgage industry.
I'm your host, Peter Benjamin.
Before we get to our episode,just a quick word from our
sponsor.
Speaker 3 (00:43):
This episode is brought to you by Consolidated
Analytics, helping credit unionsmake smarter mortgage decisions
, from origination to servicingand beyond, with expert
valuation, risk management andcompliance solutions.
They provide the insights youneed to protect your members and
grow your portfolio withconfidence.
Whether it's due diligence or acollateral risk assessment,
(01:04):
they help you navigate themarket with ease.
Learn more at due diligence ora collateral risk assessment.
They help you navigate themarket with ease.
Learn more atconsolidatedanalyticscom.
Speaker 2 (01:10):
Welcome to the fourth episode of our compliance
miniseries, where each episodewill feature an intimate
conversation with people who Iconsider to be experts in the
field and supporters of thecredit union movement.
As a reminder, with each ofthese episodes, it's our goal to
take a deep dive into variouscompliance topics that are
impacting and reshaping thecredit union mortgage industry.
(01:31):
Our next guest in thecompliance miniseries is Scott
Weintraub, Vice President ofCompliance with MQMR.
Scott, how are you doing today?
Speaker 4 (01:40):
I'm doing great, peter.
I'm so excited to be on withyou and Acuma, so thanks so much
for having me on.
Speaker 2 (01:45):
No, it's our pleasure .
We couldn't be more thrilled tohave you here One because we've
had the opportunity of gettingto know you through our
relationship with MQMR, havingMQMR be an AppGift service
provider.
You recently attended ourworkshop in Seattle.
You are one of our moderatorsfor our servicing network, so
(02:12):
we've gotten a chance to knowyou.
So we're really excited to sitdown with you and have this
conversation.
But before we really dive inand get to know you a bit more
and really talk, compliance, asalways, got to bring Justin in.
And here's the latest andgreatest happening over at Acuna
Hawk.
What's going on?
How are you doing today?
(02:33):
And please, please, tell uswhat is the latest greatest
happening over at Acuna.
I'm good, Peter.
Speaker 5 (02:37):
How are you Living the dream.
I love it, awesome.
So over here at Acuna, we aremid planning or not not even
planning we're mid getting readyto 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 eightweeks away now?
(03:00):
Roughly Right, something likethat.
Yeah, something like that.
So the speakers in the agendaare jam-packed with experts in
the mortgage industry.
I'm certain that if you come tothe event, it's going to be one
you don't want to miss, and ifyou aren't coming, then you're
going to be so sad becauseyou're going to miss the biggest
event for credit union mortgageprofessionals in the fall.
(03:21):
Registration's open, so headover to the ACME website and
come make your mark with us inDenver.
We can't wait to see you.
Aside from our annualconference, if you're looking
for additional networking andeducational opportunities, we
have our next network meeting,the Volume-Based Network.
They're going to have their Q3meeting in August, just a few
(03:42):
weeks away.
So information's already up onthe website.
So head over there and learnmore 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 (03:57):
All right, all right.
It's going to be awesome.
Can't wait for annual Annual isgoing 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 (04:10):
I mean, you've already said it this is probably
the best one that you puttogether in your time at Acumen.
I mean hands down.
Speaker 2 (04:17):
I mean, this is going to be something very, very,
very special.
Speaker 5 (04:21):
Yes, looking forward to it.
Speaker 2 (04:23):
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 verymuch.
No, scott, all right.
Turning over our sights back toyou.
You know, the actual employeepodcast is a people piece.
I mentioned that in my openingstatement.
You know I always say this.
I always go through the same,you know introduction, the first
(04:46):
question and the last questionis always the same.
You know, it's about divinginto who our speakers are,
getting to know them on a morepersonal level before we
actually really focus on themain topic.
And so the first question isalways you know who is Scott, or
who is the speaker?
(05:07):
Because I think that's the mostimportant thing about all of us
what makes us tick, what makesus who we are?
We're more than mortgageprofessionals.
We're more than the presidentof Mac.
We're more than the director ofmarketing for Actima.
We're more than everything.
So I think that's the mostimportant question.
I ask you all day today who isScott?
(05:28):
So do me a favor, walk usthrough that.
And then, of course, we'll diveinto our compliance miniseries.
So, first question who's Scott?
Speaker 4 (05:36):
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 thisindustry, I did not, from the
time I was a kid, say if only Icould grow up and work in
regulatory compliance in themortgage industry, right then
(05:56):
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 admitthat out loud.
But I spent most of mychildhood growing up in Southern
California, which is where Ilive now and I can't imagine
living anywhere else.
And then I went up to collegein the Bay Area and then out to
(06:18):
Washington DC for law school.
After law school I spent acouple of years at a law firm
and found very quickly that thatwasn't for me.
I liked the work, I didn't likethe environment and that law
firm didn't deal in mortgage atall.
It dealt mostly in healthinsurance and in defense and
(06:38):
didn't really lead to sleepingwell at night.
So, Peter, I saw an ad for ajob in-house with a mortgage
company and it said you neededtwo things.
One was three to five yearsexperience in reading laws and
interpreting them and knowinghow to comply with them.
Well, that I had.
Then, of course, it said youneeded three to five years
experience in the mortgageindustry, to which I said, well,
(07:00):
I have none, but maybewhoever's doing the hiring might
know that that part.
You could learn right what amortgage is and how that works,
and maybe I could convince themthat my learning curve would be
short.
Well, fortunately for me, that'sexactly what happened, and that
was back in 2003.
So now we're going on 22 yearswhere I've been in the mortgage
(07:22):
industry ever since and couldn'tbe happier about it exclusively
doing legal and regulatorycompliance.
So that involved working at afew different over the last 17
years before I got to MQMR a fewdifferent lenders and servicers
.
That included a servicer thatreally all they did was service
(07:44):
loans, and then some lenders whooriginated loans and either
service loans as well in-house,or had oversight and management
responsibilities over asubservicer who serviced the
loans for them.
So I've had a lot of experienceboth ways, with servicing
in-house and managing asubservicer who's doing the
day-to-day activities.
(08:05):
Then for the last five and ahalf 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, Allrelated to compliance, risk
management and audit, and so wehelp lenders, and particularly
(08:28):
servicers, with all aspects ofcompliance, of which, as you
know, Peter, there are so manythings, so many different
entities that could comeknocking on a credit union's
door, and so that's what we do,that's what my journey has been.
Speaker 2 (08:56):
I'm very confident that I'm at my last job.
We love helping companies, butin particular, I just like doing
things like this, which ishopefully passing on some
knowledge to your listeners.
The sharing of knowledge is oneof the things that makes the
credit union industry so special.
I think no matter who you talkto in our side, that's the first
thing they always say.
(09:17):
You know, credit union share,and the fact that that's
something that you thrive in,right of wanting to help,
(09:37):
wanting to really give back andshare the knowledge that you've
gained throughout all the years,that's absolutely amazing.
I mean, I sensed it when wewere in Seattle and you really
embraced everyone in that roomand all you wanted to do is, one
, listen, but two, really helpthem learn and kind of flourish.
(10:02):
I think it's awesome.
So us, us kind of asking youand your, your willingness to
kind of jump in and helpfacilitate again, you know that
that servicing network that wehave it's just only exhibits
your desire to help.
So so, scott, let's, let's,let's pivot and kind of talk
(10:25):
about, you know, here we are inthe compliance miniseries and
last year we did the, the MIminiseries, where we really
focus on, you know, theimportance of MI and kind of
debunking the myth.
This year we decided to go withcompliance because it ended up
being more timely than we everthought.
We picked compliance becauseit's it's one, it's always been
(10:47):
a moving target, but two, itjust happened to be even more of
a moving target this year thanwe ever thought it would be.
But servicing, historicallyspeaking, servicing has never
really been something thatAckman is focused on.
Yeah, we may have talked aboutit in passing, but servicing has
just only recently beensomething that our members have
really started focusing on.
(11:07):
And you know, prior to thisrecording, you and I really
started having a conversation asto why allocations when it
comes to complianceprofessionals within credit
unions, who, and really theinvestment of compliance
(11:32):
professionals on the servicingside, 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 agreat conversation we're going
to have, so let's start withthat.
So what are your thoughts onjust you know, credit unions
allocating certain resources tocompliance on the servicing side
of the business?
Speaker 4 (11:53):
Excellent place to start, peter, and first I'd like
to hit on something that youmentioned, which is what I
noticed in both Seattle andSavannah, at both of the
workshops this year.
I think you're so right whenyou said that one of the things
that's unique about creditunions in that space is how much
they share, and I saw thatfirsthand, and if I could
contribute, if I contributed tothat conversation in any small
(12:14):
way, I'm happy to do it andcan't wait to do that even more.
Another way that credit unionsare unique similar a little bit
similar to banks, but certainlydifferent than a mortgage banker
that that's all they do is thatcredit unions, they don't just
make mortgages.
It's certainly an importantpart of what they do, but it's
not the entirety of what they do.
(12:35):
And what I have found from somany conversations that I've had
with credit unions is thatbudgets are limited, and
particularly when it's relatedto compliance, which a lot of
companies don't necessarilythink that's where you make your
money in compliance, I wouldsuggest that it actually is, or
(12:55):
by saving money, you can helpyour company's bottom line, but
there isn't always enoughresources in terms of people,
dollars, systems, training, allof those different pieces to
that puzzle that helps youcreate a compliance
infrastructure.
What I found with credit unionsis, if there are resources that
(13:17):
are allocated to compliance, thelion's share of it goes to the
non-mortgage elements of whatthe credit union is doing.
Of it goes to the non-mortgageelements of what the credit
union is doing, much more so onthe depository side with those
accounts, versus specificallygoing to mortgage.
Further, when there isallocation done time, resources,
money, whatever that may berelated to compliance on the
(13:40):
mortgage side, it tends to bemore on the upfront side, on the
origination side, making theloan in the first place, as
opposed to servicing.
One of the reasons I havealways wondered about that is
because, as we all know, itcould take 30 days, 60 days,
right, maybe 90 days at theoutside to originate a loan for
(14:03):
a member.
The servicing relationshipcould last decades, right Up to
30 years.
And there are laws and when wesay laws, there are many of them
that a servicer would have tofollow for up to a period of
decades, right?
And yet, if there are resourcesallocated related to compliance
(14:24):
on the mortgage side, it tendsto be much more upfront and not
as much on the servicing side.
And so, peter, theconversations I have with credit
unions, I always start therewhat's allocated, either
internally or what vendors?
Might you have to help, or both?
And you're right, similar tohow Acuma maybe in the past,
before all the great things thatyou're doing now, wasn't as
(14:46):
focused on compliance on theservicing side.
That was true of the creditunions themselves as well, and I
think conversations that I'vehad with them have been very
eye-opening when they've thoughtabout some of these things.
Speaker 2 (14:59):
So it's interesting, right?
So, if you think about it, youhave some credit unions that
strictly portfolio and then youhave some credit unions that
sell some on the secondarymarket and they have some that
sell a whole bunch.
But let's focus on the two ofthem that I mentioned, the ones
that sell some and sell somethat sell a lot.
(15:20):
Typically, the ones that areselling on the secondary market
require some form of QC plan,sell a lot.
Typically, the ones that areselling on the secondary market
require some form of QC plan andthe QC plan does typically
require them to have some.
I know it's quality and notnecessary compliance, but it
typically requires you to havesome form of standards that you
must comply with, whether youare servicing retained or
(15:41):
servicing release, it doesn'treally matter.
You would think that they wouldinvest more resources into those
things, but I, I, I, from whatI'm seeing, it's still not the
case, right?
Like there's still very muchfalling short.
Technology is just isn't up topar or up to snuff.
Member service isn't still upto snuff, cause I think member
(16:07):
service does can very muchimpact compliance absolutely.
Uh and and now that you'resaying all these things, you're
right, you know, 30 year morelike we're.
You know we're blessed to havea 30-year mortgage.
You know, and with you know,three percent paper, there's a,
there's a fighting chance thatwe may have 30-year mortgages
(16:27):
that actually may mature for 30at 30 years right.
Speaker 4 (16:31):
Right Yep In the environment.
We're in now for sure.
Speaker 2 (16:33):
So you are, harm's right, I never actually really
sat down and thought about itthe compliance risk, on this
long-term effect of notinvesting in servicing and the
the servicing resources.
You're exposing yourself to alot of things If you only, we'll
(16:56):
say, front load your complianceresources 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 nextthing that we were going to
talk about.
It's really all the things thatyou have to focus on, right?
(17:18):
So if you were to list, likethey'll say, the top five, the
top five rules, regs, acts, youname it that could potentially
expose a credit union topotential harm and let's not
even focus on things that anNCOA or CPV auditor is going to
come and look at, but let's saythat the fundamental top five,
(17:42):
what are they?
Speaker 4 (17:43):
Yeah, absolutely, and I think, right before I get
into that, I would just say as ageneral manner, you hit on a
couple of things that are reallyimportant, which is there is a
ton of legal and compliance riskand exposure if a company is
not focused on it and doesn'thave this infrastructure in
place of compliance and youmentioned QC, that's an
(18:05):
important part of it and it doesget to compliance aspects, and
I'm going to give some of theexamples when I talk about this
top five.
And if you don't have a processor a system to look at some of
your loans, then you're in thatplace that I think Peter, you
and I talked about right beforewe jumped on in the recording,
which is you're in what Iconsider to be the worst
(18:26):
possible place, which isunknowable risk.
If you're not looking, then youdon't know where you might have
a gap or a hole, and that'sgoing to put you in a situation
where a regulator someday isgoing to tell you where your
gaps and your holes are, andthen you have two problems One,
the gap or the hole itself, andsecondly, they will say your
(18:48):
compliance infrastructure wasnot sufficient enough to have
found these yourself, and so youhave a general problem in
addition to the specific ones,so so, so it's already, you know
, is this?
Speaker 2 (19:04):
I'm not.
I guess I'm pausing because I'mtrying to think of a way to
kind of frame this up.
Yeah, is this all a result ofthe fact that a lot of the big
(19:27):
rules or changes that ourindustry has gone through in
recent time has all been on thefront end?
You know, let's think about it.
You know, atrqm Yep Trade Tradeon the front end.
You know, let's think about it.
You know atrqm yep trade trade.
Um, I guess humda, for the mostpart, 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 themajor changes happened on the
(19:53):
consumer-facing side?
Although, yes, servicing doeshave a consumer-facing component
to it, actually a majorcomponent, but that's only when
there's a need, right.
People often forget and in ourlast episode of the Compliance
(20:16):
Miniseries, mandy Phillips withASUS Quality Management
mentioned very eloquently thatpeople often forget that just
because you are not late or indefault doesn't mean you can't
call or should not call yourservicer, right?
And so that's why people oftenforget that, hey, I just need to
(20:39):
call.
I need to call and have thatinteraction, get things updated,
et cetera, et cetera, et cetera.
I digress to my conversation.
My question is are we, as anindustry, doing this to
ourselves because all of theregulations and all the changes
that came out of the CPB or youname the regulator For the most
(21:00):
part always happening on thefront side?
Speaker 4 (21:03):
So I think you are almost entirely correct.
Right, you're mostly right, andso I think, if we all go back to
what was the big thing, the bigevent that led to so many of
the new rules that we have todayyou mentioned a couple of them
the ATR rules and the TRID rulesall came out of 2008, right,
and what almost blew up?
(21:24):
The whole thing?
Right, worldwide, not even justin the United States.
The only piece I would add towhat you said so a lot happened
on the origination side.
You're right, because thoseloans that were then sold off
and broken off into pieces tospread the risk around, that all
started with the quality of theloan, or the lack thereof, of
(21:45):
the mortgage that was originatedin the first place.
The only thing I would add,peter, to what you said is the
servicing aspect of it cameabout because those loans that
were originated wrongly to beginwith, not with a borrower's
ability to repay everybody wasgetting a loan, whether really
they could afford it or not.
That led to higher rates ofdefault, right, and that's
(22:07):
really what was the impetus thatcaused the blow up that led to
this.
So you're right, while thatstarted from the quality of how
the loans originated in thefirst place.
One of the responses to it, inaddition to ATR and the ability
to repay and TRID, was also theservicing rules that amended
(22:28):
both TILA and RESPA that theCFPB did and then continues to
enforce and may continue toenforce someday in some form.
So the result of it led tothese servicing rules, which are
now so much more, so much moredetailed.
And just to hit again on whatMandy was saying to you in the
(22:49):
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 thingsthat a servicer still needs to
comply with, such as are youapplying payments proper, right?
And what about if there is anescrow account for taxes and
insurance?
Are you doing the analysis youneed to do every year?
(23:10):
Are the premiums and theproperty taxes actually being
paid?
I see problems in those areasall the time and I think, peter,
that's a good lead in.
To get back into your lastquestion, which are?
What are some of the top areas?
Maybe a top three, a top fiveareas of most concern?
So I'll start with ones thatare on the happy path, and
(23:34):
there's a couple there.
I just hit on one, which isescrow administration, and so
that is four accounts wherethere might be an escrow account
set up for the payment ofproperty taxes and insurance.
Number one companies need to beanalyzing those loans on an
annual basis, figuring out ifthere might be a shortage, right
(23:57):
.
So, for example, premiumschange, the property can be
reassessed, the amount that'sneeded for property taxes can
change, so there could be eithera shortage of funds in the
member's escrow account or asurplus of funds in the member's
escrow account.
Either way, there are actionsteps that a servicer needs to
take.
(24:17):
I can tell you, peter, from thecredit unions that I've talked
to that I've worked with.
The level of knowledge relatedto that part of it ranges from
credit unions who are on top ofit to credit unions that
couldn't even produce a reportof all of their loans that have
an escrow account to determinewhich ones needed to be analyzed
(24:39):
.
So that's a huge issue, andthose are not borrowers that are
in default, right.
So another example would besomething else that you hit on,
which is customer service.
If a borrower calls in, if theyhave a question, they make a
request.
There are rules, not just froman NCUA perspective but, for
(25:00):
example, any agencies.
If a credit union's makingloans, that might be Fannie Mae
or Freddie Mac loans, there arerequirements for when calls need
to be answered right and what'sthe pickup rate or does a call
get abandoned.
So even for loans where theborrower is paying, there are
lots of elements where aservicer needs to comply and
(25:22):
again you need people andresources and systems and
reporting enabled to do all ofthat correctly for all of your
loans.
The more loans you have, theharder that can be, especially
without good, strong processesand procedures.
Now a couple more specifics foryou for loans that maybe fall
off the happy path and they gointo default.
(25:43):
The first big area and if I wereto tell you the number one
thing, whether it's NCUA or whenit was the CFPB or any other
agency, anyone doing an exam isloss mitigation, and that
process starts from the verymoment a borrower might turn in
an application or part of anapplication, because what
happens a lot is they don't giveyou everything and so that
(26:07):
application for loss isincomplete.
Well, what's the process ofacknowledging that by the
servicer to the member?
Telling the member what'sneeded to get that application
complete, giving them a timeframe to do it and what are your
follow ups with that member toget that incomplete application
complete?
Once you get that completeapplication, the process for
(26:29):
reviewing that member forwhatever loss options might be
available, making that decisionand the timing of it.
And then another area is fees.
So if I had to say what's thefifth one, it would be fees, and
that would be whether fees arecharged at all.
Should they have been so, forexample, some of the things that
(26:50):
I've seen and that auditors hiton a lot is that a fee is
charged for a particular service, but that service wasn't
actually performed.
So you might be asking howmight that happen?
Well, an example of that couldbe a property preservation type
fee, and a lot of those fees getcharged like every 30 days or
every 60 days automatically in aservicer system, which is
(27:14):
something that's designed to behelpful, right, so that all
borrowers have the same thinghappen.
But if no one actually went outand looked at the property,
then that fee ought not to havebeen assessed.
Secondly, there could be feessuch as a late fee or an NSF fee
, and those fees often getwaived.
But the question is, doservicers have consistent
(27:36):
processes for doing that, ormight one borrower call ask to
get the fee waived?
The rep waives it right overthe phone.
The next borrower calls andthey're told no, we can't do
that for you, right?
Same company, two differentresults.
And then, just to put a bow onall of this for you, peter,
imagine, in all of these areaswhere there might be discretion,
if borrowers who get a goodresult, like a fee waive for
(28:00):
example, happen to be, let's say, a white male, right,
non-Hispanic, a majorityborrower versus someone who
maybe gets their request deniedand they happen to be a member
of a minority.
That brings up potential fairservicing issues.
And if I were to tell youanother area where companies,
credit unions, are telling me,is that even a thing?
(28:21):
Fair servicing would be at thevery top of the list of people
asking me is that a thing?
It's just like where youstarted this question, peter,
which is isn't most of thiscoming on the origination side?
A lot of folks credit unionsand elsewhere know what fair
lending is right the approval,denial of the application, the
(28:42):
price.
A lot of people don't know eventhat fair servicing is a thing,
or how to do it or what you'resupposed to do once you know
that it is a thing.
Speaker 2 (28:53):
OK, it's interesting and I love the fact that you
brought the fees.
I mean, that's been in thespotlight a lot recently.
Okay, so NCUA CFPB have beencoming in and doing a lot of aud
(29:14):
.
It that our listeners reallyneed to pay attention to and
(29:38):
make sure that they are notdoing or correcting as soon as
possible so they're not gettingfindings.
Speaker 4 (29:44):
Excellent question and, just at the outset, what I
would add to it is despitewhat's been going on, for
example, at the CFPB or maybe atother agencies, all of the laws
and regs that servicers need tocomply with are still there.
They're still on the books,right?
They haven't been repealed, andso, whether someone comes out
(30:04):
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 becoming to your door right now.
That's not a thing, Right, andit ought not be a thing for a
servicer, because eventually youwill get audited and they will
(30:26):
be looking back at what you'vedone since the last time they
came in or before.
Now to your point what areexaminers find?
Now to your point what areexaminers finding?
I will start with the placewhere examiners start, and
that's with a credit union'spolicies and procedures.
So, number one do you have them?
Do you have them for allaspects related to your
(30:48):
servicing operations?
Are they sufficient to knowthat if your employees followed
your policies and procedures,would they then be servicing
loans compliantly and, evenbeyond that, giving those
members a good experience forthat up to 30-year period where
you're servicing their loan.
And so one thing that examinersfind all the time is that there
(31:13):
is not sufficient policies,procedures, infrastructure.
Peter, you hit on qualitycontrol and actually having a
process of reviewing loans on amonthly and quarterly basis and
coming up with reports that sayeither there's no issues or we
did find some issues right.
This last minute applicationwasn't considered or it wasn't
(31:35):
considered timely, just as anexample and are there action
steps that get taken by theservicer based on the results of
those audits?
So the lack of a sufficient QCprogram is another finding
that's very common.
A third one is the one you andI were just discussing, and
that's fees Either theassessment of fees when they
(31:56):
ought not to have been assessedand or the waiving of fees in a
manner that's not consistentamong members or among borrowers
.
And I would go and that's also agood segue back to policies and
procedures.
In addition to maybe not havingenough or they're not being
sufficient, the other thing thatthe NCUA or other auditors will
(32:18):
do is they will say fine, theseare your policies and
procedures, this is what you sayyou do.
Now I, the auditor, am going tolook at, to start with, a small
sample of your loans.
Why are they doing that?
Because they want to know areyou in actual practice, are you
doing what your policies andprocedures say you do?
(32:40):
Or, if you are, are you doingthem all the time or only some
of the time?
And so that's something that'sfound very commonly, that your
policies and procedures say Xand what actually is happening
at the credit union, either someof the time or more than some
of the time, is Y, and obviouslyX doesn't equal Y and that's a
(33:03):
problem, right?
So, lastly, I'd hit on lossmitigation we touched on that as
well, Actually the applications, getting them from complete to
complete, as well as thedecision and our different
borrowers, who are similar,getting similar decisions or are
they being treated differently.
So that's really about a goodfive areas of the most common
(33:24):
findings, not only that I seefrom audits and examinations,
but that I see when working withcredit unions.
Speaker 2 (33:30):
Yeah, I love that you brought up.
You know policies, procedures.
You know throwing processes inthere 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 sitdown and document.
You know everyone's roles andresponsibilities, type them up
(33:51):
and make sure everything wasproperly documented.
And what I found was you knowthat was oftentimes a saving
grace during any audit be ableto 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 themthat they didn't question
(34:17):
anything.
Right?
Speaker 4 (34:18):
The conversation stopper.
Right, which is my favoritething.
You don't want conversationstarters, you want conversation
stoppers.
Speaker 2 (34:24):
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 anddo a TRID audit.
They want to see our TRIDpolicy and procedures, fully
expecting us not to have it.
Thankfully, I was brought in toto to write all of them, so I
(34:47):
did, and it was the fastestaudit that the FDIC ever did at
a community bank because they, Ishowed them, passed and they
were out.
They looked at two loans.
The two loans passed.
We were good, right, and so Ilove that you said that, because
it was always one of the thingsthat saved my bacon, because I
(35:08):
always had those ready.
Speaker 4 (35:11):
Such a success story, right To think about where the
bank was before you got thereand what that exam would have
been like if you hadn't beenthere and done it Right, it's
easy just to document and theydon't be pretty.
Speaker 2 (35:25):
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 thatyou're supposed to be doing,
you're good.
Speaker 4 (35:33):
Right, that's right.
It's two steps.
Right.
You got to document it and thenmake sure your process actually
matches it.
Speaker 2 (35:40):
That's right.
Two steps, yeah, that's exactlyit.
Well, scott, we gotta starttransitioning.
But before we do last question,like I said, first question
always the same, last questionis 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 finalthoughts on servicing compliance
for credit unions and thingsthat they can do to really make
(36:03):
sure that they're staying ahead,or anything in general?
Because I mean, again, this isa new frontier for Acuma.
Our credit unions are reallystarting to be really hungry for
this type of content.
I we want to be better, so anyfinal thoughts on this whole
(36:28):
conversation?
Speaker 4 (36:29):
Absolutely.
I'd say two things.
Number one, so two words tounderstand and to look.
So by understand I mean, again,I think a lot of people know
things like trade and ability torepay, but to understand all of
the different requirements onthe servicing side, from the
time that loan is boarded untilthe time it's resolved,
(36:51):
hopefully with a payoff and nota foreclosure or something like
that.
So understand what all theobligations are for you
servicing loans or, if you use asub, what they're supposed to
be doing and, again, areas whereI'm happy to help answer
questions and bounce ideas offwith folks.
That's number one.
Understand.
Number two is look, meaning tolook at your operations, from
(37:14):
your policies and proceduresfirst, then to your actual
processes, to see if it matchesand by doing that, to look at
loans as well and to see, at theend of the day, how are we
doing so that you're not in thisplace 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
(37:37):
in an action plan to correct it, and then that risk becomes no
risk.
If you don't know what yourrisk is, then, among other
things, peter, it's a constantstate of anxiety, right.
So understand and look.
Speaker 2 (37:51):
Okay, love it All.
Right, real last question.
Yeah, it kind of connects backto the first question, but what
keeps you going?
What keeps you ticking?
You're just like everyone else.
We take one foot out of bedevery single morning and then we
just keep pushing forward.
What keeps you going?
Speaker 4 (38:07):
I will tell you.
I think if I would say that inone word, it would be passion.
I am passionate aboutcompliance.
I always have been, and now forthe last five and a half years
where it's been not just at onecompany but helping many, peter,
I am passionate about helpingcompanies comply.
One of the reasons for that isbecause, if a company does, if
(38:29):
all the credit unions listeningto us today a compliant
infrastructure and culture willhelp save money and help make
money.
Why do I say that?
Because you'll save money withfines and all kinds of
reputational damage, lawsuits,refunds, all of those different
things.
But you'll also, in addition tosaving money, you'll make money
because your borrowers, yourmembers, are going to have a
(38:51):
great experience and they'regoing to refer friends and
family to you because they wantthem to have the same great
experience that you had.
So people don't usually thinkof compliance this way, but you
can both save and make moneywhile being more compliant at
the same time.
That's my passion, peter.
That's what I set out to doevery day.
Speaker 2 (39:11):
I love it.
Great answer, great answer.
All right, scott, let'stransition to the second segment
of the podcast and again in thecompliance miniseries, we are
going to do the most requested,fan favorite segment of dad
jokes.
So prior to the recording, Iasked you to come prepared with
two dad jokes.
So here's what we're going todo You're going to do your two
dad jokes, justin is going to dohis two dad jokes and I will
(39:34):
wrap up with my two dad jokes.
Sound good?
Speaker 4 (39:37):
I love it.
So I'm first in this in theextravaganza of dad jokes.
Speaker 2 (39:40):
You most certainly are so.
Speaker 4 (39:43):
I did my homework.
Peter, I tell you I like thesecond one even more than the
first, so I'm going to warm youup with the first one and then
give you the second one.
So the first one is why did thebanana go to the doctor?
He had a splitting headache.
Not bad, that's a great guess.
(40:07):
The actual answer is because hewasn'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 firstoriginal French fries were not
in fact made in France?
(40:28):
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 (40:46):
That's good, all right, justin.
Speaker 4 (40:48):
All right, Justin.
Speaker 5 (40:49):
All right, let's see if I can top those.
What did one wall say to theother wall?
You don't know, I'll meet youat the corner.
Speaker 4 (41:08):
I'll accept that.
I'll accept that alright.
Speaker 5 (41:11):
And then why do cows wear bells?
Why, because their horns don'twork.
Speaker 3 (41:16):
Why do cows wear?
Speaker 5 (41:17):
bells, why Because?
Speaker 4 (41:19):
their horns don't work, all right.
Speaker 2 (41:22):
All right, all right, got a few, okay.
A horse walks into a bar.
The bartender asks why the longface?
The horse, not being able tocomprehend human language,
promptly shits on the floor andleaves no, okay sorry, I'm
(41:47):
getting.
Speaker 4 (41:47):
It.
Took me a second there you go.
Speaker 2 (41:48):
Thank you, I appreciate it uh, all right,
here's my next one.
Um, did you know that beforecrowbars were invented, crows
mostly drink alone?
Speaker 4 (42:01):
I like that one okay, good, thank you.
Speaker 2 (42:03):
Apparently all mine flopped today, but thank you
very much for laughing at thatsecond one scott, you're welcome
, I'll give this a redemptionone um, why did a pig dressed in
black never get bullied?
Speaker 5 (42:21):
I don't know.
Speaker 2 (42:21):
Why?
Because Batman was sworn toprotect Gotham.
Speaker 5 (42:27):
There you go.
I like that one.
Speaker 2 (42:31):
All right.
Well, scott, thank you verymuch for being such a great
episode on this compliance, thisAcumen On Point podcast,
compliance mini episode ofcompliance miniseries.
Truly enjoyed the conversation.
And again thank you very muchfor being one of the moderators
for our compliance miniseries,our servicing miniseries.
(42:52):
Excuse me, but also again thankyou to MQMR for being one of
our acumen services providers.
I truly appreciate everythingthat you and the rest of MQMR do
for our members and the creditunion industry.
Speaker 4 (43:08):
Absolutely our pleasure.
Thanks so much, peter.
I enjoyed it as well.
Speaker 2 (43:11):
Of course, and, justin, thank you very much.
Speaker 5 (43:14):
Thanks, Justin, Of course it was my pleasure.
Speaker 2 (43:16):
All right, and to quickly close out, thank you
again to Consolidated Analyticsfor sponsoring today's episode
and to all of you.
We know your time is valuable.
Thank you for tuning in to thelatest episode of Acuna's On
Point Podcast.
We hope you enjoyed it.
Until next time.
Be well, my friends.
Speaker 1 (43:30):
Thanks for listening.
We'll see you next time at theAcuma On Point podcast.
If not already, be sure tosubscribe and give us a
five-star rating For more greatepisodes and information.
Be sure to visit us online atacumaorg and to get the latest
updates.
Head over to our LinkedIn page.
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The Burden
The Burden is a documentary series that takes listeners into the hidden places where justice is done (and undone). It dives deep into the lives of heroes and villains. And it focuses a spotlight on those who triumph even when the odds are against them. Season 5 - The Burden: Death & Deceit in Alliance On April Fools Day 1999, 26-year-old Yvonne Layne was found murdered in her Alliance, Ohio home. David Thorne, her ex-boyfriend and father of one of her children, was instantly a suspect. Another young man admitted to the murder, and David breathed a sigh of relief, until the confessed murderer fingered David; “He paid me to do it.” David was sentenced to life without parole. Two decades later, Pulitzer winner and podcast host, Maggie Freleng (Bone Valley Season 3: Graves County, Wrongful Conviction, Suave) launched a “live” investigation into David's conviction alongside Jason Baldwin (himself wrongfully convicted as a member of the West Memphis Three). Maggie had come to believe that the entire investigation of David was botched by the tiny local police department, or worse, covered up the real killer. Was Maggie correct? Was David’s claim of innocence credible? In Death and Deceit in Alliance, Maggie recounts the case that launched her career, and ultimately, “broke” her.” The results will shock the listener and reduce Maggie to tears and self-doubt. This is not your typical wrongful conviction story. In fact, it turns the genre on its head. It asks the question: What if our champions are foolish? Season 4 - The Burden: Get the Money and Run “Trying to murder my father, this was the thing that put me on the path.” That’s Joe Loya and that path was bank robbery. Bank, bank, bank, bank, bank. In season 4 of The Burden: Get the Money and Run, we hear from Joe who was once the most prolific bank robber in Southern California, and beyond. He used disguises, body doubles, proxies. He leaped over counters, grabbed the money and ran. Even as the FBI was closing in. It was a showdown between a daring bank robber, and a patient FBI agent. Joe was no ordinary bank robber. He was bright, articulate, charismatic, and driven by a dark rage that he summoned up at will. In seven episodes, Joe tells all: the what, the how… and the why. Including why he tried to murder his father. Season 3 - The Burden: Avenger Miriam Lewin is one of Argentina’s leading journalists today. At 19 years old, she was kidnapped off the streets of Buenos Aires for her political activism and thrown into a concentration camp. Thousands of her fellow inmates were executed, tossed alive from a cargo plane into the ocean. Miriam, along with a handful of others, will survive the camp. Then as a journalist, she will wage a decades long campaign to bring her tormentors to justice. Avenger is about one woman’s triumphant battle against unbelievable odds to survive torture, claim justice for the crimes done against her and others like her, and change the future of her country. Season 2 - The Burden: Empire on Blood Empire on Blood is set in the Bronx, NY, in the early 90s, when two young drug dealers ruled an intersection known as “The Corner on Blood.” The boss, Calvin Buari, lived large. He and a protege swore they would build an empire on blood. Then the relationship frayed and the protege accused Calvin of a double homicide which he claimed he didn’t do. But did he? Award-winning journalist Steve Fishman spent seven years to answer that question. This is the story of one man’s last chance to overturn his life sentence. He may prevail, but someone’s gotta pay. The Burden: Empire on Blood is the director’s cut of the true crime classic which reached #1 on the charts when it was first released half a dozen years ago. Season 1 - The Burden In the 1990s, Detective Louis N. Scarcella was legendary. In a city overrun by violent crime, he cracked the toughest cases and put away the worst criminals. “The Hulk” was his nickname. Then the story changed. Scarcella ran into a group of convicted murderers who all say they are innocent. They turned themselves into jailhouse-lawyers and in prison founded a lway firm. When they realized Scarcella helped put many of them away, they set their sights on taking him down. And with the help of a NY Times reporter they have a chance. For years, Scarcella insisted he did nothing wrong. But that’s all he’d say. Until we tracked Scarcella to a sauna in a Russian bathhouse, where he started to talk..and talk and talk. “The guilty have gone free,” he whispered. And then agreed to take us into the belly of the beast. Welcome to The Burden.