RSK Compliance Solutions, LLC is a full service regulatory compliance and loan review consulting Firm, serving community financial institutions of all sizes. RSK’s clients are concentrated in New York, New Jersey, Pennsylvania, and the surrounding regions. RSK Compliance provides an in-depth skill set of regulatory compliance services both as a function of support to compliance officers and as an outsourced solution. RSK’s range of services include design and implementation of custom policies and procedures to meet federal and state regulatory requirements, risk assessments, system and security compliance, ongoing consultation, and compliance related training for personnel and the Board of Directors.

We are also a leading provider of independent loan review services to Banks, Credit Unions and Fin Tech companies. Our in depth process provides a unique level of transparency over our credit rating process which our clients, regulators and third parties that place reliance on assessing the overall health of the loan portfolio, have come to appreciate.

RSK IQ is our new online Compliance Question and Answer center, intended to provide a streamlined, effective, and faster way to have our best compliance experts answer your inquiries on relevant regulatory compliance matters. RSK.IQ is the quickest and smartest way to connect your compliance question with the right Subject Matter Expert on the topic. Rather than calling and asking or e-mailing a question to just any one consultant, RSK.IQ sends your inquiry to RSK's full family of compliance specialists, and matches your question to the best consultant on the topic.

RSK.IQ Question of the Month 1/18/21

Loan Origination Services and Transfers

Issue/Inquiry

Bank A will accept mortgage loan applications from its customers, which will be assigned to Bank B. Bank B will make the TRID disclosures, do the underwriting, make the credit decision, and close the loans in its name. Bank A will perform origination services for Bank B prior to closing, for which it will be compensated. Bank B will then transfer the loans to Bank A, which will service the loans. Will this arrangement satisfy the requirements of RESPA?