President & Managing Director
Brokers Compliance Group
In Part One of this two-part series, I noted that “the regulator will determine whether advertisements and promotional materials provide timely, clear, and understandable information about the existence of costs, payment terms, penalties, or other terms and charges, the reasons for their imposition, and the salesperson’s compensation from cross-sales.”[i]
- Advertising Manual, with a host of supporting forms;
- Record Retention, containing all advertisements and reviews thereof; and
- Forms and Checklists, constituting all loan products and origination methods.