COMPLIANCE MANAGEMENT SYSTEM MANUAL

COMPLIANCE MANAGEMENT SYSTEM MANUAL FY 2016 Movement Mortgage, LLC s Compliance Management System This policy was last revised February 8, 2016.

Table of Contents Section 100 Introduction...3 Section 200 Management Oversight...5 Section 201 Executive Team Meetings... 6 Section 300 Compliance Program...9 Section 301 Compliance Department Overview... 9 Section 302 Policies and Procedures... 10 Section 303 Compliance Policies... 10 Section 303.1 Federal Laws and Regulations... 11 Section 303.2 State Laws and Regulations... 18 Section 303.3 Additional Policies... 19 Section 304 Compliance and Company Procedures... 20 Section 305 Training and Education... 20 Section 305.1 Monthly Compliance Training Schedule... 21 Section 305.2 Training Content Maintenance... 22 Section 305.3 Training Non-Compliance Corrective Action... 22 Section 305.4 Executive Team Training... 22 Section 306 Monitoring and Corrective Action... 22 Section 306.1 Compliance Checks... 22 Section 307 Regulatory Examinations... 24 Section 400 Response to Consumer Complaints... 26 Section 500 Compliance Audit... 29 1

SECTION 100 INTRODUCTION 2

Section 100 Introduction Compliance has always been a cornerstone of Movement Mortgage, LLC s business strategies. Valuing compliance ensures that Movement Mortgage, LLC upholds all relevant laws and regulations and further protects Movement Mortgage, LLC and consumers from harm. Movement Mortgage LLC s Compliance Department has created a Compliance Management System to ensure that compliance is a part of every aspect of Movement Mortgage, LLC s lending process and that all Movement Mortgage LLC management personnel and employees understand their responsibilities within Movement Mortgage, LLC s Compliance Management System. To accomplish this, Movement Mortgage, LLC has created a Compliance Management System that: Establishes the compliance responsibilities of each employee; Communicates those responsibilities to each employee; Ensures that every aspect of the lending process is legally compliant through monitoring and testing by various Movement Mortgage, LLC departments; Assigns the responsibilities of maintaining legal compliance to the Compliance Department, along with every manager and employee through the performance of his or her day-to-day responsibilities; Reviews all aspects of sales and operations to ensure responsibilities are carried out effectively and all legal requirements are met; and Takes corrective action and updates all company policies and procedures as necessary. Movement Mortgage, LLC s Executive Team has adopted this Compliance Management System Policy. Additionally, the Executive Team delegates to the Compliance Department the further development of all policies and procedures related to Movement Mortgage, LLC s Compliance Management System and the day to day oversight of the Compliance Management System including, monitoring changes in applicable laws and recommending to the Executive Team amendments to Movement Mortgage, LLC s policies and ensuring that all compliance training remains up to date and in adherence with Movement Mortgage, LLC s Compliance Management System. All Movement Mortgage, LLC operations and sales personnel are responsible for understanding and complying with all compliance requirements as outlined in these policies and procedures and are required to participate in all applicable compliance training as designated by the Compliance Department. Movement Mortgage, LLC has developed this Compliance Management System according to the examination guidelines prescribed by the Consumer Financial Protection Bureau (CFPB). This guidance requires four interdependent control components which are: Members and Management oversight; Compliance Program; Response to Consumer Complaints; and Compliance Audit. This Compliance Management System Policy Manual will discuss Movement Mortgage, LLC s policies as they relate to all four control components. 3

SECTION 200: MANAGEMENT OVERSIGHT 4

Section 200 Management Oversight Movement Mortgage, LLC s Executive Team functions as an important part of Movement Mortgage, LLC s overall organizational structure. The Executive Team consists of various Executive personnel and management of Movement Mortgage, LLC. The Executive Team, in relation to the Compliance Department and among its other functions that lie outside of compliance, retain the sole authority for: 1) Reviewing and approving Movement Mortgage, LLC s policies for the Compliance Management System; 2) Appointing and approving Movement Mortgage, LLC s Chief Compliance Officer; 3) Designating additional compliance management personnel as needed; 4) Designating sufficient resources for compliance management and oversight; and 5) Altering Movement Mortgage, LLC s Compliance Management System as required by law. Movement Mortgage, LLC s Executive Team delegates the following responsibilities to the Compliance Department: 1) Establishing a Compliance Management System; 2) Establishing Key Compliance Policies for Movement Mortgage, LLC; 3) Establishing compliance procedures to maintain compliance with Movement Mortgage, LLC s Compliance Management System; 4) Ensuring adequate fair lending compliance systems are implemented to maintain appropriate fair lending compliance; 5) Ensuring all marketing materials disseminated to the public are compliant pursuant to state & federal law, as well as being compliant with Movement Mortgage, LLC s policies and procedures; 6) Maintaining compliance with current federal and state laws and regulations; 7) Maintaining compliance oversight over Movement Mortgage, LLC s sales locations; 8) Developing and implementing adequate compliance training for all of Movement Mortgage, LLC; 9) Reviewing and determining compliance related to new product and service offerings; 10) Receiving and responding to state and federal examination requests; 11) Reviewing the consumer complaint management system; 12) Ensuring process for handling consumer complaints remains compliant with all laws and regulations; and 13) Monthly reporting on compliance related aspects of Movement Mortgage, LLC to the Executive Team. Additionally, Movement Mortgage, LLC s Executive Team reviews Quality Control (QC) findings and Vendor Management oversight findings as provided by QC and Vendor Management personnel as specified in Movement s QC Department and Third Party Vendor Management Policy and Procedures. Movement Mortgage, LLC s Executive Team shall operate within the boundaries enumerated in this Compliance Management System and those enumerated in Movement Mortgage, LLC s Operating Agreement. Movement Mortgage, LLC s Operating Agreement shall negate and supersede any portion 5

of this Compliance Management System with which it conflicts. The Compliance Department shall be governed by and operate under the authority of the Compliance Management System. Section 201 Executive Team Meetings Movement Mortgage, LLC s Executive Team holds regular weekly and monthly meetings to discuss operational and logistical aspects of Movement Mortgage, LLC business. The Executive Team also holds additional ad hoc meetings as required due to any unforeseen circumstances necessitating a meeting. The Executive Team keeps regular meeting minutes for every monthly meeting and memorializes the same through the use of executed resolutions that are executed at the beginning of each subsequent meeting. Executive Team meeting minutes and corresponding resolutions may not address all items discussed at the Executive Team meetings, but should provide general descriptions of all major discussion topics. Movement Mortgage, LLC Executive Team meeting minutes and executed resolutions are kept in a safe and secure location by Movement Mortgage, LLC indefinitely. The Executive Team has the authority to designate the form, location, and person responsible for keeping the above described Executive Team meeting minutes and resolutions. The agendas for the weekly meetings are kept in a safe and secure location by Movement Mortgage, LLC indefinitely, but no minutes or resolutions are kept for these weekly meetings. The Executive Team shall discuss the following at a minimum during its monthly meeting as related to compliance: 1) Any Movement Mortgage, LLC policies submitted for review and approval; 2) Any formal designations for Movement Mortgage, LLC Executive and/or Management personnel; 3) Monthly reports from all reporting departments at Movement Mortgage, LLC, including the Compliance Department; 4) Any new product and service offerings, including compliance and fair lending considerations related to the same; 5) Any corrective action based on the monthly Compliance Report or other department reports, internal reviews or audits, and federal or state examinations or audits; 6) Movement Mortgage, LLC business reviews of all departmental cost allocations for the company, including the Compliance Department; 7) Review of any weekly Department Manager Meeting agenda items that have been escalated for Executive Team review; Additionally, the Executive Team shall review, discuss, and approve all key Movement Mortgage, LLC policies on an annual basis, which shall at a minimum include Movement Mortgage, LLC s: 1) Compliance Management System; 2) Federal Regulation Compliance Policy; 3) Anti-Predatory Lending Policy; 4) Anti-Money Laundering / Bank Secrecy Act Policy; 5) Red Flag Identity Theft Policy; 6

6) SAFE Act Policy; 7) Loan Officer Compensation Policy; 8) Appraisal Independence Policy; 9) Gramm-Leach-Bliley / Consumer Privacy Policy. The Executive Team makes all Executive Team meeting minutes and resolutions available to the Compliance and Legal Departments for review as needed to ensure they meet the requirements of all federal and state laws and regulations. Information related to Executive Team training and education is described in Section 305 below. 7

SECTION 300: COMPLIANCE PROGRAM 8

Section 300 Compliance Program Section 301 Compliance Department Overview The mission of Movement Mortgage, LLC s Compliance Department is to provide excellent regulatory oversight for all of Movement Mortgage, LLC s initiatives, processes and outcomes and to advise, inform, audit and reform those same initiatives, processes and outcomes as needed to maintain strict regulatory compliance throughout the company and its affiliates. Movement Mortgage, LLC s Compliance Department provides the regulatory framework on which all activities of the company are grounded. The Compliance Department verifies regulatory compliance in all of Movement Mortgage, LLC s policies and procedures and reviews all policies and procedures on a periodic basis to ensure proper regulatory compliance. In addition, the Compliance Department provides compliance information and education for the entirety of Movement Mortgage, LLC s employees in order to maintain a high level of compliance with law and regulation throughout the company. The Chief Compliance Officer (CCO) will develop a team of Compliance Associates whose responsibilities will include regulatory research and reporting, assisting with regulatory exams and audits, implementation of regulatory controls and compliant compliance policies and procedures throughout the company, and ensuring compliance of policies and procedures implemented outside this Compliance Management System. The CCO will also develop a team of Administrative Compliance professionals whose responsibilities will include oversight of the compliance training program, Loan Officer (LO) licensure and continuing education, branch and company licensure, key policy manual compliance review, regulatory reporting, and the auditing of marketing initiatives. A sound Compliance Program is essential to Movement Mortgage, LLC s business plan. Movement Mortgage, LLC s Compliance Program is administered by the CCO who has the authority to implement the Compliance Department and Compliance Program independently of other Movement Mortgage, LLC business units to ensure its autonomy and ability to maintain the company s compliance with all relevant federal and state laws and regulations. The goals of Movement Mortgage, LLC s Compliance Program are: 1) Prevent or reduce regulatory violations; 2) Protect consumers from non-compliance and associated harms; 3) Help align business strategies with outcomes, and; 4) Serve as a training and reference tool for employees. Movement Mortgage, LLC has modeled its Compliance Program according to the examination guidelines issued by the CFPB. The three components of the Compliance Program examination guidelines are: 1) Policies and Procedures 2) Training 3) Monitoring and Corrective Action Each component will be covered in detail in the following sections. 9

Movement Mortgage, LLC s Compliance Program has been designed to maintain compliance with all relevant and applicable federal and state laws and regulation over the entire course of all of the company s product lifecycles. It has also been designed to prevent regulatory violations and prevent injury to consumers. Movement Mortgage, LLC s Compliance Program is implemented by various policy and procedure manuals, all of which will be updated as needed as changes in federal and state laws and regulations occur. Section 302 Policies and Procedures Movement Mortgage, LLC is subject to both federal and state laws and regulations. In order to maintain compliance with all relevant state and federal laws and regulations, Movement Mortgage, LLC has created policies and procedures to address compliance concerns throughout the company. All policy and procedure manuals are designed to prevent violations of laws and/or regulations, as well as to identify and prevent harm to consumers. All of Movement Mortgage, LLC s policies shall be made available for all current employees for review. Movement Mortgage, LLC procedure manuals are available to all appropriately designated employees based on the employee s department and job title. Section 303 Compliance Policies All of Movement Mortgage, LLC s key policies as stated in Section 201 above are reviewed and approved by the Executive Team prior to becoming effective and are designed to cover the entire lifecycle of all of Movement Mortgage, LLC s product and service offerings. The Compliance Department conducts a periodic review of all policies to ensure that all policies are compliant with all state and federal law. This approach maintains consistency and keeps policies current with all applicable laws and regulations. All Movement Mortgage, LLC s policies shall cover every loan s lifecycle while the loan is in Movement Mortgage, LLC s control. The Compliance Department is responsible for updating key policy manuals as stated in Section 201 above based on: 1) Changes to federal and state laws and regulations; 2) The recommendation of the Executive Team; and 3) The findings of federal and state examinations. Below is a list of federal and state regulations which apply to Movement Mortgage, LLC, a brief summary of each regulation, and the location of Movement Mortgage, LLC s policies regarding the same. Compliance with all of the following laws and regulations is monitored by the CCO, the Compliance Department, and various other departments, including but not limited to the Quality Control Department, Qualified Mortgage Department, and Third Party Vendor Management Department, to ensure Movement Mortgage, LLC s ongoing compliance with its own internal policies, as well as federal and state laws and regulations. 10

Section 303.1 Federal Laws and Regulations Movement Mortgage, LLC, as a provider of consumer financial products, fully complies with all federal consumer financial laws and appropriately addresses and prevents any violations of the law and potential consumer harm through its Compliance Management System, written policies, and written procedures. Movement Mortgage, LLC has organized its Compliance Management System to include compliance with consumer-related federal laws that fall within the purview of the CFPB, and other appropriate federal regulatory agencies with oversight authority over Movement Mortgage, LLC. The monitoring and implementation of compliance activities of Movement Mortgage, LLC are performed by its Compliance Department in order to maximize effective implementation, training, monitoring, and corrective action. The following sections will describe the federal laws applicable to Movement Mortgage, LLC s lending activities. Movement Mortgage, LLC has created policies and/or procedures related to each that allows Movement Mortgage, LLC to implement, train, monitor, and administer corrective action related to its compliance with each specific law. The descriptions of the laws and regulations listed below are not to be considered comprehensive, but are rather brief, non-exhaustive summaries of each laws characteristics and/or requirements. For complete information regarding Movement Mortgage, LLC s policy related to each of the federal laws described below, please consult the applicable policy manual referenced in each section. Section 303.1.1 Bank Secrecy Act / Anti-Money Laundering Laws The Currency and Foreign Transactions Reporting Act of 1970, known as the Bank Secrecy Act (BSA), requires financial institutions to identify and prohibit money laundering activities. Non-bank residential lenders and originators are considered financial institutions for the purposes of the act. The BSA requires the maintenance of records and the reporting of cash purchases of negotiable instruments in the amount of $10,000.00 or more and the reporting of any suspicious activity that may indicate money laundering. The BSA has been modified and revised through multiple laws enacted since it was originally passed into law in 1970. The Code of Federal Regulation currently requires all finance and loan companies to have policies and procedures in place to prevent the company from facilitating money laundering and financing terrorist activities. At a minimum, companies subject to the act are required to: 1) Develop, implement and monitor policies and procedures designed to prevent money laundering; 2) Designate a compliance officer who will oversee the anti-money laundering program, ensuring it is monitored, updated, and that all employees understand their reporting obligations under the act; 3) Provide independent testing and monitoring of the program to ensure its adequacy; and 4) Maintain documentation as required by the act. 11

Additionally the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act) and the Fraud Enforcement Recovery Act of 2009 (FERA) also require certain acts and procedures be adhered to by mortgage lenders. Movement Mortgage, LLC s AML/BSA policy can be found in its Anti-Money Laundering Policy Manual. Section 303.1.2 Equal Credit Opportunity Act The Equal Credit Opportunity Act (ECOA) of 1974, implemented by Regulation B, makes it unlawful for a creditor to discriminate against any credit applicant on the basis of race, color, religion, national origin, sex, marital status, age, receipt of public assistance funds, or the consumers good faith use of any rights allowed under the Consumer Protection Act. ECOA also requires creditors to inform credit applicants if they have been granted or denied credit within thirty (30) days of receiving the applicant s application, as well as stating a specific reason why credit is being denied or approved at a lesser amount than for which the applicant initially applied. If adverse action is taken, all applicants are entitled to a written notice of the adverse action. Discrimination, as defined under the act, is prohibited when a lender: 1) Intentionally treats an applicant differently based on a protected class ( Intentional Discrimination ); or 2) When the creditor s policies and procedures have an adverse impact on a protected class ( Disparate Impact, some exceptions to impact may apply). Ultimately discrimination should never occur during any part of the credit transaction. Creditors are prohibited from discouraging potential applicants from applying for credit based on protected class status. The CFPB was granted regulatory control over ECOA by the Dodd-Frank Act in 2010, and has amended ECOA to require creditors to provide borrowers with free copies of all appraisals and any other written valuations connected to credit applications secured by first liens on real property. Movement Mortgage, LLC s ECOA Policy can be found in its Federal Compliance Policy Manual. Section 303.1.3 Fair Credit Reporting Act The Fair Credit Reporting Act (FCRA) of 1970, implemented by Regulation V, as applicable to Movement Mortgage, LLC, regulates the collection and use of consumer credit information. The FCRA requires creditors to adopt policies and procedures which ensure that the creditor provides complete and accurate information to the credit bureaus regarding the borrower s credit line with the creditor. Additionally, the act requires creditors to provide notice to consumers that the creditor may report adverse action credit information about the consumer s credit to the credit bureaus. Notice must also be given regarding the limits and the purposes for which creditors may use and disclose the personal financial information of consumers. Adverse action under the act includes unfavorable changes in credit terms, denying or cancelling credit, offering credit with terms less favorable than requested, and denying employment or promotion based on credit. Movement Mortgage, LLC s FCRA Policy can be found in its Federal Compliance Policy Manual. 12

Section 303.1.3.1 Fair and Accurate Credit Transactions Act The Fair and Accurate Credit Transactions Act (FACTA) of 2003 was enacted as an amendment of the FCRA and it allows consumers to obtain one free credit report per year from one of the three major consumer credit reporting companies. Additionally, the act also prohibits lenders from issuing credit to consumers with fraud alerts indicated on the consumer s credit report unless the lender has policies and procedures in place to be able to reasonably confirm the applicant s identity. The FACTA also requires that notice be sent to new loan applicants if their credit information will materially and adversely affect the terms of their loans. Movement Mortgage, LLC Mortgage s FACTA Policy can be found in its Federal Compliance Policy Manual. Section 303.1.4 Fair Housing Act The Fair Housing Act (FHAct), Title VIII of the Civil Rights Act originally adopted in 1968 and subsequently amended in 1988, prohibits discrimination related to buying and selling homes based on race, color, national origin, religion, sex, familial status, or handicap. The FHAct mandates Movement Mortgage, LLC not refuse to make a loan, refuse to provide information regarding loans, impose different loan terms, discriminate in appraising property, refuse to purchase a loan, or set different terms or conditions for a loan based on one of the act s protected classes. Additionally, the Department of Housing and Urban Development (HUD) has issued guidance relating to advertisements for real property, which also cannot relay any lending preferences based on one of the protected classes. A few major lending practices deemed illegal under the FHAct include: 1) Redlining Denying loans in certain neighborhoods when the individual is otherwise eligible for credit (this may also include offering less favorable terms on this basis); 2) Excessively Low Appraisals Loans cannot be made on the basis of excessively low appraisals; 3) Onerous or Varying Terms and Conditions Lenders cannot require additional information or adherence to different procedures from prospective borrowers solely based on a protected class; 4) Racially Biased Advertisements for Properties Includes solicitations for borrowers speaking a certain language; and 5) Racial Steering It is illegal to guide borrowers into or away from certain geographic areas based on a protected class. Movement Mortgage, LLC s FHAct Policy can be found in the Federal Compliance Policy Manual. Section 303.1.5 Gramm-Leach-Bliley Act / Privacy of Consumer Financial Information Regulation P of the Gramm-Leah-Bliley Act (GLBA), also known as the Privacy of Consumer Financial Information (PCFI) Act, limits the amount and instances where lenders can disclose nonpublic personal consumer information to nonaffiliated third parties. Lenders are required to provide notices to consumers about the lender s privacy policies, including any conditions 13

where consumer information may be disclosed to nonaffiliated third parties, and provide consumers a reasonable option for opting out of the disclosure of personal information to these third parties. The GLBA requires that privacy notices be disclosed to consumers when: 1) The consumer first engages the lender; 2) On an annual basis after the consumer engages the lender while the transaction is ongoing; and 3) If the policy notice is amended. Lenders are required under the act to have policies and procedures in place to address all interactions with consumers to make sure nonpublic personal information is not inadvertently disclosed outside of the constraints of the act. Movement Mortgage, LLC s GLBA / PCFI Policy can be found in its Consumer Privacy Policy Manual and its document retention and destruction policies, can be found in its Document and Email Retention Policy Manual. Section 303.1.6 Homeowners Protection Act The Homeowners Protection Act (HPA) of 1998, also known as the PMI Cancellation Act, sets guidelines for the cancellation and/or termination of purchase mortgage insurance (PMI), along with applicable disclosure and notice requirements. The HPA sets forth the requirements and standards for borrowers requesting that their PMI be cancelled, along with requirements and standards for when lenders must automatically cancel PMI. Lenders are required to provide disclosures related to the act s requirements to borrowers at consummation of the loan and on an annual basis. Movement Mortgage, LLC s HPA Policy can be found in its Federal Compliance Policy Manual. Section 303.1.7 Home Mortgage Disclosure Act The Home Mortgage Disclosure Act (HMDA) of 1975, as implemented by Regulation C and amended by the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA) and the Federal Deposit Insurance Corporation Improvement Act of 1991 (FDICIA), requires financial lenders to provide mortgage data to the public to ensure lenders are providing financing to equally qualified applicants on reasonable terms and conditions throughout the United States. HMDA requires reporting on various elements of the borrower s application including loan type, property location, ethnicity, sex, race, and gross income amongst others. The data provided to the government is analyzed to ensure lenders are serving the housing needs of their communities, public-sector investments are being distributed as needed, and to also identify discriminatory lending patterns violating ECOA or FHAct or other laws and regulations. Movement Mortgage, LLC s HMDA Policy can be found in its Federal Compliance Policy Manual. Section 303.1.8 National Flood Insurance Act / Flood Disaster Protection Act The National Flood Insurance Act (NFIS) of 1968 (reformed in 1994 and 2004) and the Flood Disaster Protection Act (FDPA) of 1973 requires lenders to determine if properties for which they are making loans fall within a special flood hazard area (SFHA), as determined by FEMA. 14

If so, the lender must notify the borrower if flood insurance will be required as a condition of receiving a loan. According to the acts, lenders must require flood insurance for properties located within SFHAs and may require it on properties outside of SFHAs. The amount of flood insurance coverage is set by the 2007 Mandatory Purchase of Flood Insurance Guidelines and will be set at the lesser of the following: Outstanding principal balance of the loan(s); Maximum amount of coverage available under the National Flood Insurance Program; or The full value of the building and/or its contents (100% replacement cost value). Lenders are required to notify borrowers of any requirement to purchase flood insurance for property for all new and existing loans. Movement Mortgage, LLC s Flood Disaster Protection Act Policy can be found in its Federal Compliance Policy Manual. Section 303.1.9 Real Estate Settlement Procedures Act The Real Estate Settlement Procedures Act (RESPA) of 1974, as implemented by Regulation X, was created to stop lenders from charging inflated fees to consumers by requiring lenders to provide disclosures to borrowers reflecting approximate costs for a loan, currently via a Good Faith Estimate (GFE) and a HUD-1, and soon to be altered by the requirements of the TILA-RESPA Integrated Disclosure Rule (TRID), discussed below. RESPA protects consumers related to lending activities by: 1) Prohibiting kickbacks, fee-splitting, and unearned fees; 2) Prohibiting lenders from requiring the use of specific title insurance companies; 3) Limiting the amounts lenders may require to be escrowed for property related fees; and 4) Specifying federal disclosure requirements from application through post-closing. Furthermore, RESPA protects consumers in relation to servicing activities by setting forth guidelines for handling consumer inquiries, requiring notices for transferring servicing rights, setting escrow limitations, eliminating PMI in certain situations, and requiring certain disclosures related to escrow amounts and charges to be paid by the borrower. Movement Mortgage, LLC s RESPA Policy can be found in its Federal Compliance Policy Manual. Section 303.1.10 Secure and Fair Enforcement for Mortgage Licensing Act The Secure and Fair Enforcement for Mortgage Licensing Act of 2008 was enacted to provide uniform licensing standards for Mortgage Loan Officers (MLOs) and certain regulated institutions throughout the country in order to aid in identifying bad actors and to drive dishonest and incompetent MLOs out of the industry. The act requires states to create their own system for monitoring MLOs or to participate in the NMLS Registry system. State regulations and standards may exceed the minimums required by the SAFE Act, but they cannot fall below the minimum standards. The system makes certain employment and criminal history information available to the public so that bad actors may be held accountable for their actions. Movement Mortgage, LLC s SAFE Act Policy can be found in its SAFE Act Policy Manual. 15

Section 303.1.11 Servicemember s Civil Relief Act The Servicemember s Civil Relief Act protects service men and women from being sued while in active military service of the United States. Courts require proof that an individual is not currently on active duty prior to allowing an adverse action to commence against an individual. The SCRA can affect borrowers rights through the act s cap of six percent (6%) interest on loans to qualified parties, restricting repossession and foreclosure rights of lenders, installing protections for cancelling leases and insurance, and installing protections related to evictions. Movement Mortgage, LLC s SCRA Policy can be found in its Federal Compliance Policy Manual. Section 303.1.12 Unfair, Deceptive or Abusive Acts or Practices Act The Unfair, Deceptive or Abusive Acts or Practices Act (UDAAP), as implemented by Regulation Z, allows the CFPB to define and prohibited unfair, deceptive and abusive acts related to lenders providing financial products and services. As defined by the CFPB: 1) An act is unfair when it: (1) causes or is likely to cause substantial injury to consumers, (2) the injury is not reasonably avoidable by consumers, and (3) the injury is not outweighed by countervailing benefits to consumers or competition. 2) An act is deceptive when it: (1) misleads or is likely to mislead the consumer, (2) the consumer s interpretation of the representation, omission, act, or practice is reasonable under the circumstances, and (3) the misleading representation, omission, or practice is material. 3) An act or practice is abusive when it: (1) materially interferes with the ability of a consumer to understand a term or condition of a consumer financial product or service OR (2) takes unreasonable advantage of (a) a lack of understanding on the part of the consumer of the material risks, costs, or conditions of the product or service, or (b) the inability of the consumer to protect its interests in selecting or using a consumer financial product or service, or (c) the reasonable reliance by the consumer on a covered person to act in the interests of the consumer. Movement Mortgage, LLC s UDAAP Policies can be found in its Federal Compliance Policy Manual, its Advertising and Marketing Policies and Procedures Manual, and its MSA Department Manual. Section 303.1.13 Truth in Lending Act The Truth in Lending Act (TILA), as implemented by Regulation Z, and originally enacted as Title I of the Consumer Credit Protection Act of 1964, and as amended by Dodd-Frank, standardized the disclosures related to the terms and conditions of obtaining credit. Additionally, it creates uniform standards for calculating and disclosing the actual cost of credit so that consumers can make intelligent and informed choices. It also provides standards for advertising credit terms. TILA provides different standards for different types of loans and includes limits for mortgage loan originator (MLO) compensation, anti-steering provisions related to MLO compensation, and penalties for violating the act. 16

Movement Mortgage, LLC s TILA Policy can be found in its Federal Compliance Policy Manual. Section 303.1.13.1 Appraisal Independence Requirements The Dodd-Frank Act, passed in 2010, enacted independence requirements for appraisals related to consumer credit transactions by amending TILA. The TILA amendment, called the Appraisal Independence Requirements (AIR), forbids interested parties in consumer credit transactions from compensating, coercing, extorting, colluding with, instructing, inducing, bribing, or intimidating a person or company conducting an appraisal for the purpose of altering the value of the property being appraised or to affect the independent judgment of the appraiser, as well as making it unlawful to mischaracterize the appraised value of the property securing the credit, attempting to influence an appraiser to encourage a target value, and withholding or threatening to withhold timely payment to the appraiser for services rendered. The act does allow interested parties to consider additional information when conducting an appraisal, provide additional details or explanation for the appraiser s value conclusion, and to correct errors in the appraisal report. The requirements call for mandatory reporting of suspected violations of the requirements and Uniform Standards of Professional Appraisal Practice and implement monetary penalties for violations. Movement Mortgage, LLC s AIR Policy can be found in its Appraisal Independence Policy Manual. Section 303.1.13.2 Higher-Priced Mortgage Loans Appraisal Rule The Higher-Priced Mortgage Loan Appraisal Rule (HPML), a CFPB amendment to TILA effective for all loan applications received after January 18, 2014, provides additional appraisal standards for higher-priced mortgage loans. If a loan falls subject to this rule, the MLO must use a licensed appraiser in compliance with the Uniform Standards of Professional Appraisal Practice (USPAP) and Financial Institutions Reform, Recovery and Enforcement Act, among the other provisions of the HPML Rule. A higher-priced mortgage loan is a loan secured by a consumer s principal dwelling as a first lien with an APR exceeding the average prime offer rate by 1.5% or more, a first lien jumbo loan with an APR exceeding the average prime offer rate by 2.5% or more, and subordinate liens with an APR exceeding the average prime offer rate by 3.5% or more. Qualified mortgages, reverse mortgages, bridge loans under 1 year, initial construction loans, loans secured by new manufactured homes, and loans secured by trailers and mobile homes are excluded from the HPML Rule. Movement Mortgage, LLC s HPML Policy can be found in its Federal Compliance Policy Manual. Section 303.1.13.3 Home Ownership and Equity Protection Act Rule The Home Ownership and Equity Protection Act (HOEPA) was enacted in 1994 as an amendment to the TILA to address abusive practices in refinances and closed-end home equity loans with high interest rates or high fees. All loan application received after January 18, 2014, require additional disclosures, avoidance of certain loan terms, and allows for 17

additional consumer protections and counseling. Additionally, this amendment created enhanced remedies for violations of the law related to issues with high-cost mortgages. Movement Mortgage, LLC s HOEPA Policy can be found in its Federal Compliance Policy Manual. Section 303.1.13.4 Mortgage Disclosure Improvement Act The Mortgage Disclosure Improvement Act (MDIA) allows consumers to be more informed regarding the terms of a mortgage loan prior to closing. The act prevents lenders from collecting fees prematurely, requires the issuance of updated disclosures if material changes occur with loan rates, and mandates a seven day waiting period from the time the lender mails the initial disclosures before a loan is allowed to close. Movement Mortgage, LLC s MDIA Policy can be found in its Federal Compliance Policy Manual. Section 303.1.13.5 TILA-RESPA Integrated Disclosure Rule The TILA-RESPA Integrated Disclosure Rule (TRID), effective October 3, 2015, combines the Good Faith Estimate (GFE) and the Initial TIL Disclosure into a single disclosure called a Loan Estimate. Additionally, it also combines the Final HUD-1 Settlement Statement and the Final TIL Disclosure into a single disclosure called the Closing Disclosure. Both of these documents have specific formatting requirements required by the CFPB and have been designed so that consumers can better understand the actual cost of the credit for which they are applying. TRID requires lenders to provide the Loan Estimate within three business days of receiving a consumers loan application. Lenders are also required to provide the Closing Disclosure three business days prior to the consummation of the loan. TRID does not apply to HELOCs, reverse mortgages, or mortgages secured by a mobile home or dwelling not attached to real property. Movement Mortgage, LLC s TRID Policy can be found in its TRID Policy Manual. Section 303.2 State Laws and Regulations As a provider of consumer financial products, Movement Mortgage, LLC fully complies with each state s consumer financial laws. Movement Mortgage, LLC appropriately addresses any violations and attempts to prevent any additional future violations of law and associated harms to consumers through its Compliance Management System and written policies and procedures. Movement Mortgage, LLC has organized its Compliance Program to include compliance with state laws that fall within the purview of all the applicable regulatory state agencies that oversee Movement Mortgage, LLC. All compliance related activities of Movement Mortgage, LLC are performed by its Compliance Department to ensure that all Movement Mortgage, LLC policies and procedures are most effectively implemented, trained, and monitored for compliance. Movement Mortgage, LLC has complied with all state regulatory examination requests and report findings to date. Movement Mortgage, LLC maintains all examination results, and correspondence related to the same and uses the results of these examinations to improve internal processes and to ensure its current and future compliance with state law and regulation. 18

For additional information related to state laws and regulations, please see Movement Mortgage, LLC s State Compliance Policy Manual. Section 303.3 Additional Policies Movement Mortgage, LLC has additional policies for addressing various other internal and external issues that may arise during the course of operations. These policies will be briefly discussed below with references where to find additional information. Section 303.3.1 Advertising and Marketing Policy Movement Mortgage, LLC has developed and maintains a policy for ensuring compliance with advertising laws and regulations. Marketing and advertising for the company is designed to be clear, non-misleading, fair, and accurate in order to provide consumers with information relevant to the mortgage origination process. Movement Mortgage, LLC requires that all advertising materials be truthful, non-deceptive, reasonable and fair, and include all appropriate, required disclosures. Movement Mortgage, LLC s Policy for advertising can be found in the Marketing and Advertising Policy and Procedures Manual. Section 303.3.2 Anti-Predatory Lending Policy Movement Mortgage, LLC has developed and maintains a policy for maintaining compliance with all fair lending laws and regulations. The fair lending goals of the company are designed to be realistic and attainable, while ensuring all applicants are given equal and impartial treatment in the marketing, origination, processing, approval, closing, and servicing of their home mortgage. No employee of Movement Mortgage, LLC shall discriminate in granting or fixing the terms of credit against any applicant for credit based on race, creed, color, national origin, age, sex, marital status, or disability. Movement Mortgage, LLC s Policy for Anti-Predatory Lending can be found in its Anti-Predatory Lending Policy Manual. Section 303.3.3 Loan Officer Compensation Policy In an effort to comply with both federal and state guidelines, Movement Mortgage, LLC has created a policy to govern loan officer compensation. The loan officer compensation policy sets out the criteria and compensation requirements for all Movement Mortgage, LLC loan officers, as well as documentation requirements related to the same. Movement Mortgage, LLC s loan officer compensation policy is designed to prevent loan steering. Movement Mortgage, LLC s Policy relating to Loan Officer Compensation can be found in its Loan Officer Compensation Policy Manual. Section 303.3.4 Red Flags Identity Theft Policy Movement Mortgage, LLC has developed and maintains a policy for identifying, detecting, and responding to red flags related to issues concerning the identity of all of the consumers with whom it interacts. This policy is designed to protect the personal information of all applicants and borrowers for 19

the company s covered accounts. Movement Mortgage, LLC s red flag policy includes regular audits and monitoring to ensure its effectiveness and compliance with all applicable federal laws. Movement Mortgage, LLC s Policy for Identifying and Responding to Identity Red Flags can be found in its Red Flags Identity Theft Policy Manual. Section 304 Compliance and Company Procedures All of Movement Mortgage, LLC s procedure manuals are drafted by each department of the company and are reviewed and approved by that department s manager(s). All procedures are reviewed at least annually by each department s manager for which the procedure applies. Any changes are appropriately updated and the procedure manual is re-approved. Additionally, the Compliance Department reviews all approved department procedure manuals on a periodic basis to ensure compliance with all state and federal laws and regulations and all company adopted policies. The Compliance Department is responsible for advising appropriate departments upon its receipt of legal and regulatory compliance updates so that those departments can update their procedure manuals based on updates related to federal and state laws and regulations as needed. The Compliance Department will also advise appropriate departments of potential changes needed for departmental procedures based on the findings of federal and state examinations on an as needed basis. All Movement Mortgage, LLC procedures implement Movement Mortgage, LLC s policies, so the procedures should not conflict with any policies. If any procedures conflict with a policy, the policy shall supersede and negate the procedure. Procedural manuals outline Movement Mortgage, LLC s procedures in detail and may provide flow charts and checklists for employees to utilize on the job. Employees will be given access to all applicable procedure manuals to his or her department. Section 305 Training and Education Movement Mortgage, LLC is committed to the training and education of Movement Mortgage, LLC s Executive Team, Management, Operations Staff, and Sales Staff. Training and education is divided into the following areas: 1. New Hire Training - Required of New Hires within 10 days of initial hire and covers all policies in the Federal Regulatory Compliance Manual. The New Hire course is designed to give each new employee the basic understanding of federal and state regulations that impact the mortgage industry. Any departmental training that the new employee receives can build on the regulatory foundation received through this course. 2. Monthly Operational Compliance Training - Occurs monthly for all employees working in an operations center and follows the monthly training schedule in Section 305.1 below. The monthly training is designed to focus on aspects of the federal regulations that impact the daily work of employees in the operational centers at Movement Mortgage, LLC. All content and the 20

summary exam of each month s training focus on specific items of importance as related to specified job functions. 3. Annual Sales Compliance Training - Occurs between November and March of each year and covers all of the information in the Federal Regulatory Compliance Manual. The focus of this training is on compliance items of specific importance to the role of those working in branch offices, specifically, Loan Officers, Loan Officer Assistants, Market Leaders and other administrative employees who work with borrowers at a branch location. A semi-annual training may be implemented to cover any changes in law or regulation since the annual training on an ass needed basis. 4. Special Executive Team Training For member of the Executive Team. Includes, but is not limited to, an annual Compliance Summit, attendance at various regulatory conferences, and Compliance Associate training as directed by the Executive Team and established at Executive Team meetings. For additional information, please see Section 305.4, Executive Team Training, below. 5. Monthly Compliance Tip of the Month focuses on topics of primary concern to the Compliance Department and can be launched at any time to either sales staff, operational staff, or both. Section 305.1 Monthly Compliance Training Schedule The CCO reserves the right to change this schedule to include new or updated topics. Month Topic January February March April May June July August September October November Unfair, Deceptive or Abusive Acts and Practices/Mortgage Acts and Practices Act Gramm Leach Bliley/Reg. P/TILA Reg Z Anti-Money Laundering/Bank Secrecy Act/Fraud Fair Housing Act/Equal Credit Opportunity Act National Flood Insurance Program/ Homeowner s Protection Act (PMI Act) S.A.F.E. Act and Dodd Frank (definition of originating) TILA (w TRID) RESPA (w TRID) HOEPA Service Members Civil Relief Act FACTA/FCRA 21

December HMDA Section 305.2 Training Content Maintenance The content of all compliance training courses is updated at least annually and at any time that a regulatory change mandates an update. Section 305.3 Training Non-Compliance Corrective Action All compliance training programs have a 30 day grace period. If the due date of any training module becomes 10 days past due, the Compliance Training Team will issue an email to the non-compliant employee and will copy the employee s supervisor, indicating that a warning is pending for the employee. Should the employee not complete the training before the end of the grace period, a warning is recorded in the employee s personnel file. Once an employee has received two warnings, the CCO, or other compliance personnel as designated by the CCO, will implement a plan for corrective action including, but not limited to, catching up on compliance training and completing future trainings on time. Should the employee choose not to follow the corrective action plan, further disciplinary action will occur, potentially up to and including termination. Section 305.4 Executive Team Training Movement Mortgage, LLC s Executive Team participates in Executive Team specific compliance training in several different capacities. Throughout the year short, supplemental, in-person training sessions developed by Compliance Associates are presented to the Executive Team on an ad hoc basis. On an annual basis, the Executive Team attends an Executive Team Compliance Summit and other regulatory conferences. The Annual Executive Team Compliance Summit is conducted by outside counsel who discuss regulatory updates and issues with senior management. Annual regulatory conferences are conducted by individual regulators. Movement Mortgage, LLC s Senior Executive Team attend various conferences throughout the year for additional compliance training. In addition to conferences, the Executive Team completes Movement Mortgage, LLC Compliance Training, either the annual sales compliance training or monthly compliance training as applicable to that person s job function. Section 306 Monitoring and Corrective Action Section 306.1 Compliance Checks Movement Mortgage, LLC utilizes monitoring compliance program elements that seek to identify procedural or training weaknesses in an effort to provide for a high level of compliance by promptly identifying and correcting weaknesses. The Compliance Department currently performs a number of compliance checks on a daily, weekly, monthly, or quarterly basis, that are designed to determine whether our transactions and other consumer contacts are handled according to Movement Mortgage, LLC s policies and procedures. 22

Compliance issues are monitored and presented at the weekly Department Manager Meeting and at each monthly Executive Team Meeting. Both of these forums are used to present compliance issues as needed and result in process changes and corrective action when applicable. Additionally, the Compliance Manager reviews the results of the compliance checks and notifies the CCO and the appropriate department heads of any infractions. The CCO compiles a report of the compliance checks and presents it to Movement Mortgage, LLC s Executive Team at the monthly Executive Team meeting. The department representatives present at the Executive Team meeting are responsible for reviewing the infractions and determining if infractions resulted from a deficiency in the policy and procedure or from a lack of training. If the deficiency is from a policy and procedure error, the problem and any solutions are presented at the weekly Quality Control meeting. At the weekly Quality Control meeting a decision is made to determine whether the problem is with the actual policy and procedure or whether the current policy and procedure is not being followed appropriately. If it is determined a new policy and procedure is needed, or the current policy and procedure needs to be updated, an individual present at the weekly Qualify Control meeting is selected to submit a Movement process change submission form utilizing the Movement HUB. All process changes are reviewed and discussed at the weekly manager meeting and what changes are needed, if any, and who will be responsible for implementing and following through with those changes will be determined at that time. Section 306.1.1 Scheduled Compliance Checks Movement Mortgage, LLC performs a number of compliance checks on a regular basis. Additional information about all of the compliance checks performed, what the check monitors, and the frequency of the check can be found in the Compliance Monitoring Procedure Manual. New or additional Compliance Checks are added based on, but not limited to, the following criteria: 1. New regulations are added by state or federal agencies; 2. An internal compliance audit identifies any deficiencies or areas of weakness; 3. A state or external audit identifies any deficiencies or areas of weakness; 4. A pattern of consumer complaints exposes a weakness regarding a particular regulation; 5. Training and testing results reveal an area of weakness in understanding a particular regulation; 6. The CCO or Executive Team determines that adequate checks are missing to monitor a particular regulation or process; and / or 7. The Executive Team or CCO identifies a need for any additional check(s). In addition to the Compliance Department monitoring and corrective action as described above, the Internal Audit Department, Third Party Vendor Management Department, and Quality Control Departments further monitoring and examinations as relevant to their departmental functions. The Internal Audit Department performs routine monitoring examinations of Movement Mortgage, LLC s compliance with various federal laws and regulations. The Quality Control Department performs routine loan documentation monitoring of every loan originated by Movement Mortgage, LLC to ensure compliance with various federal laws and regulations. 23

Section 307 Regulatory Examinations Movement Mortgage, LLC is subject to various state, federal, and regulatory examinations and audits. The result of these examinations and audits are paramount to Movement Mortgage, LLC s maintenance of proper licensure to conduct lending business. The Compliance Department takes the lead for state and federal regulatory examinations these examinations as it relates to drafting and submitting examination responses, gathering required examination response documentation, and assigning examination requirements to other departments within Movement Mortgage, LLC as needed. Depending on the information the examination seeks, the entire examination may be performed by a department outside of the Compliance Department. Examination reports from the entity examining Movement Mortgage, LLC are retained and responded to generally by the Compliance Department. The Compliance Department utilizes the information contained in the examination reports, along with any information gathered as a result of the examination, to implement process changes in order to keep Movement Mortgage, LLC in compliance with all relevant state and federal laws and regulations. The Compliance Department works with other affected departments and the Executive Team in order to implement any process changes. 24

SECTION 400: RESPONSE TO CONSUMER COMPLIANTS 25

Section 400 Response to Consumer Complaints The third component of Movement Mortgage, LLC s Compliance Management System is the Response to Consumer Complaints Program, titled internally as the 7 R System. Movement Mortgage, LLC has modeled and developed its 7 R System after the examination guidelines proscribed by the CFPB for responding to consumer complaints. The goals of the 7 R System are to quickly acknowledge a customer s complaint, provide timely and satisfactory resolution, categorize and record the consumer complaint for further analysis, give feedback and training to the appropriate parties, and review procedures so that systematic consumer complaints are reduced and the policies and procedures related to systematic problems are properly addressed. The seven steps of the 7 R system are as follows: 1. Receive Complaint; 2. Review Complaint; 3. Record and Categorize the Complaint; 4. Raise to Senior Management (Escalate), as necessary; 5. Resolve Complaint; 6. Retrospective Corrective Action, as necessary; 7. Reassess Procedures, based on Complaint data and individual complaints. Movement Mortgage, LLC defines a Complaint as: A written expression of dissatisfaction with or an allegation of wrongdoing by Movement Mortgage, LLC, one of its lawful representatives, or one of its third party service providers for which it is responsible, made by a consumer, whether or not actually rising to the level of violating the law, that requires a response explicitly or implicitly. All complaints submitted to Movement Mortgage, LLC as defined above are considered official complaints for complaint monitoring and response purposes. This includes, but is not limited to, complaints received from consumers through the CFPB, the Better Business Bureau, written U.S. mail, and direct email. Movement Mortgage, LLC also monitors and responds to all expressions of consumer dissatisfaction about Movement Mortgage, LLC received through any channel, not just those meeting the definition listed above. Movement Mortgage, LLC tracks all expressions of consumer dissatisfaction, along with its responses, and performs trending analysis on complaint data in order to improve its internal processes and procedures. Any information regarding consumer complaints is sent to the Solutions Team via email at Solutions@movement.com, via U.S. Mail at 841 Seahawk Circle, or via telephone at (757) 227-3385. The Compliance Department performs all oversight functions of the Solutions Team and utilizes assistance from the Legal Department as described in Movement Mortgage, LLC Solutions Team Procedure Manual. The Solutions Team is ultimately in charge of appropriately researching, responding to, and resolving consumer complaints and is responsible for recording the complaint, along with all of its associated documentation and correspondence, in a centralized complaint database. It is paramount that 26

complaint information be properly labeled and stored to ensure compliance with all state and federal regulation and to ensure Movement Mortgage, LLC s ability to properly handle and respond to all consumer complaints. Although all official complaints must be received in writing by Movement Mortgage, LLC, this policy and Movement Mortgage, LLC s Consumer Complaint Response Procedure Manual generally refer to all expressions of consumer dissatisfaction as a complaint because the policy and procedures for handling all expressions of consumer dissatisfaction are the same. All complaints involving servicing issues are handled by Movement Mortgage, LLC s Servicing Department and/or its sub-servicer, Dovenmuehle Mortgage, Inc. (DMI). All servicing related complaints are sent to Movement Mortgage, LLC s Servicing Department for resolution. The Servicing Department creates a monthly summary of all servicing related complaints and reports this data to the Solutions Team on a monthly basis for its aggregation with all other complaints. Recording and tracking complaints, complaint information, and complaint resolutions helps Movement Mortgage, LLC identify trends and patterns related to the complaints it receives which in turn allows for the modification and adjustment of policies, procedures, and training where appropriate. The Compliance Department reviews all consumer complaint information stored in the consumer complaint database on a monthly basis to ensure that complaints are properly categorized and handled, and to identify trends related to complaints received by Movement Mortgage, LLC. The Compliance Department has access to the consumer complaint database and record system in order to perform these checks in its role of performing oversight of the Solutions Team. In addition to identifying trends in consumer complaints, the Compliance Department is responsible for addressing any trends found in consumer complaint data by: 1) Recommending amendments to policies and procedures as appropriate; 2) Administering appropriate training related to policies and procedures changes as needed; and 3) Determining corrective action for policy and procedure violations brought to Movement Mortgage, LLC s attention through consumer complaints. 27

SECTION 500: COMPLIANCE AUDIT 28

Section 500 Compliance Audit The Internal Audit Department s (hereinafter IA Department ) coverage of compliance matters is the final component of Movement Mortgage, LLC s Compliance Management System. The IA Department reviews Movement Mortgage, LLC s compliance in regards to federal consumer financial laws, as well as Movement Mortgage, LLC s adherence to its internal policies and procedures. In order to maintain its integrity, the IA Department is independent of Compliance Department and the Compliance Program as described above. The IA Department is also independent of all Movement Mortgage, LLC business related functions, including customer sales, service, and operations. While the IA Department does interact with other Movement Mortgage, LLC departments it is not controlled by any of the departments it reviews. This enables the IA Department to effectively administer its reviews and audits without undue influence from any other department. The IA Department s goal is to provide Movement Mortgage, LLC s Executive Team or its designated committee(s) with its findings which note whether policies and standards adopted by the Executive Team to guide risk management and compliance are being implemented and adhered to in order to provide for the level of compliance and consumer protection as established by the Executive Team. The IA Department is also tasked with identifying any significant gaps in Movement Mortgage, LLC s policies and procedures and makes recommendations regarding how to improve and address deficiencies with the company s policies and procedures. The IA Department performs examinations, reviews, and audits related to the compliance of laws applicable to Movement Mortgage, LLC on an on-going basis, according to a schedule the IA Department establishes on a yearly basis. These examinations, reviews, and audits involve appropriate department managers and the Executive Team or its designated committee(s), all of whom are given a chance to interact with the IA Department and respond to the reports produced by the IA Department. All of these examinations and reviews are examined, approved, and re-approved, as applicable, by Movement Mortgage, LLC s Executive Team or its designated committee(s) as stated in the Internal Audit Policy Manual. As a result of the examinations, reviews, and audits the IA Department draws preliminary conclusions about the strength, accuracy, adequacy, and weaknesses or policies and procedures, confirms policies and procedures are adhered to, and offers recommendations about areas that need improvement. All IA Department reviews and audit results are disclosed to the appropriate parties and lead to timely corrective action by the IA Department, the IA Department Manager, the CCO, Movement Mortgage, LLC s Executive Team or its designated committee(s), and the appropriate applicable department(s) as needed and as appropriate. Movement Mortgage, LLC s Procedures relating to the Internal Audit Department and its functions can be found in its Internal Audit Department Manual. 29