Compliance Management Systems
-- A CFPB Mandate --


The CFPB requires all non-depository consumer financial services companies, including Independent Mortgage Banks, to implement a Compliance Management System (CMS) to ensure adherence to federal consumer financial laws. MBS offers expert guidance based on the CFPB Examiner’s Guide to help you understand and implement a CMS that meets regulatory expectations. This is not optional—it's a CFPB mandate.
MBS can build your CMS:
Understanding the Purpose of a CMS
MBS educates your team on why a Compliance Management System is essential and what the CFPB expects from non-depository lenders. We help you avoid common pitfalls by focusing on the full mortgage product lifecycle—from origination to servicing.
Implementing the 7 Essential Components
MBS ensures your CMS includes these critical components:
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Board & Management Oversight
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Written Policies and Procedures
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Comprehensive Training Programs
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Ongoing Monitoring
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Responsive Action Plans
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Qualified Written Request (QWR) Protocols
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Independent Quality Control (QC)
Preparation & Confidence in Execution
Our team guides you through proper implementation to ensure your CMS can withstand regulatory scrutiny. With a focus on documentation, testing, and accountability, you'll know your system is built right—and know how to prove it.
Defining Core CMS Goals
We help you establish the five primary goals of a strong CMS:
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Clear Responsibility
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Internal and External Communication
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Documented Policies
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Effective Controls
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Corrective Action when needed
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Customized CMS Design
We tailor each CMS to match your institution’s size, complexity, and risk profile. Whether using internal resources or vetted third parties, MBS helps design and implement a scalable, sustainable system built for your specific needs.
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Mock CFPB Exam & Readiness
MBS conducts mock CFPB exams to assess your readiness and strengthen weak spots before an actual review. This test-run gives your team confidence and ensures every CMS component is working as intended.