OBJECTIVE AND PURPOSE OF THE COMPLAINTS HANDLING POLICY:
Pacific Mortgage Planning LLC (PMPFIRM), seeks to maintain it’s reputation as a mortgage lender that delivers high quality professional services. PMPFIRM is also committed to maintaining it’s responsiveness to the needs and concerns of it’s clients. This policy is designed to provide guidance on the manner in which PMPFIRM receives and handles complaints made against the firm, which includes it’s principals, partners, employees, and consultants, as may be applicable. The object of this policy is to assist the firm in resolving complaints in an efficient, effective and professional manner.
FEDERAL REGULATORY BACKGROUND:
In response to the 2007-08 U.S. housing crisis and resulting recession, the United States Congress passed the Secure and Fair Enforcement for Mortgage Licensing Act (the “SAFE ACT”) in 2008 to establish a national licensing system for all state regulators to use in licensing mortgage professionals. The Consumer Financial Protection Bureau (CFPB) was subsequently created in 2011 ( the same year the final SAFE ACT was published) as a result of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The CFPB is the federal agency that holds primary responsibility for regulating consumer protection in the United States and enforces the SAFE ACT through the National Mortgage Licensing System (NMLS).
NMLS was created by the Conference of State Bank Supervisors (CSBS) and the American Association of Residential Mortgage Regulators. It is owned and operated by the State Regulatory Registry LLC, a wholly owned subsidiary of CSBS. NMLS is the sole system of licensure and record for mortgage companies and Mortgage Loan Originators for most U.S. state and territorial agencies including Florida.
PMPFIRM aligns it’s procedures with the current best practices as may be required and amended by the NMLS from time to time.
DEFINITION OF A COMPLAINT:
This policy is intended to address complaints made to PMPFIRM. While complaints may have several meanings, PMPFIRM has defined a complaint under this policy as: “An expression of dissatisfaction made to an organization related to it’s services, or the complaints-handling process itself where a response or resolution is explicitly or implicitly expected.” Any person or organization (complainant) ho is dissatisfied with a service provided by the firm, for any reason, may contact PMPFIRM to make a complaint. A complaint may be oral or written. At times, complaints can be made by way of negative feedback, which may not require a resolution or formal follow-up. While this type of feedback is valuable, the Policy does not apply to feedback of this nature because all complaints received by PMPFIRM shall be responded to in writing.
GUIDING PRINCIPLES OF EFFECTIVE COMPLAINTS HANDLING:
PMPFIRM has implemented the following guiding principles of effective complaints handling:
Our complaints handling policy is available on our website and hard copies will be made available upon request to anyone.
Our complaints handling policy is readily accessible to all clients, principals, partners, employees and consultants, as may be applicable. This policy is easy to understand and includes details on making and resolving complaints.
Receipt of each complaint will be promptly acknowledged. Complaints will be handled in an efficient and effective manner. Complainants will be treated courteously and kept informed of the progress of their complaint through the complaint-handling process.
Each complaint is addressed in an equitable, objective and unbiased manner though the complaint-handling process.
There will be no fees assessed to the complainant for making a complaint.
Personally identifiable information concerning the Complainant is actively protected from disclosure unless the Complainant expresses consent to it’s disclosure.
All principals, partners, employees and consultants of PMPFIRM, as may be applicable, including the president, are committed to efficient and fair resolution of complaints PMPFIRM actively solicits feedback from it’s clients on a regular basis and acknowledges a client’s right to complaint.
All principals, partners, employees and consultants accept responsibility for effective complaints handling. The president will ensure that, where appropriate, issues raised in the complaints handling process are reflected in principal, partner or employee performance evaluation, if applicable.
PMPFIRM’S complaints handling process will be reviewed periodically, and at least annually, in order continually enhance efficient delivery of effective outcomes.
HANDLING A COMPLAINT
HOW A COMPLAINT MAY BE MADE:
When a complaint is about a particular engagement, service, principal, partner, employee or consultant, and when the complainant is familiar with the person(s) working o the complainants matter, the complainant may wish to address the complaint to a specific or the most appropriate person, orally, by letter email or fax. Where possible, complaints should be made in writing so that the details of the complaint are clear and complete. If the complainant is not sure whom the complaint should be referred, or feels that it would be inappropriate to address the complaint to a specific person, the complainant should contact the President of PMPFIRM. The President, Chad F. Olafson, taking full responsibility for the actions of PMPFIRM and it’s principals, partners, employees and consultants, as applicable, is therefore also responsible for all quality assurance and risk management affairs of the firm. His contact particulars are as follow:
Chad F. Olafson
President / Principle Broker
Pacific Mortgage Planning LLC
510 NE 4th Ave Suite 2
Camas, WA 98607
INFORMATION REQUIRED FOR WHEN MAKING A COMPLAINT:
When making a complaint, the following information should be provided by the Complainant to PMPFIRM:
· Name of the company or person(s) involved, the individual’s title, and all relevant contact particulars of the complainant.
· Complainant’s relationship with PMPFIRM (i.e., the nature of Complainant’s engagement with PMPFIRM and whether you are an existing or prospective client)
· Contact person at PMPFIRM to whom Complainant would wish to address the complaint.
· Nature of the complaint (including what was said or done resulting in the need to file a complaint, and when the conduct giving rise to the complaint occurred.)
· Details of the PMPFIRM principal, partner, employee or consultant involved (if applicable)
· Copies of any documentation supporting the complaint (i.e., contracts, account statements, disclosure documents, canceled checks or money wires, sales materials and advertisements.
ASSISTANCE WITH MAKING A COMPLAINT:
If the complaint requires assistance in formulating or lodging a complaint, the Complainant should not hesitate to contact the President of PMPFIRM at any time (please reference contact info provided above)
ACKNOWLEDGEMENT OF COMPLAINTS:
PMPFIRM is committed to acknowledging all complaints promptly upon receipt. Once a complaint has been received, an initial review of the complaint will be undertaken. PMPFIRM will work to resolve complaints within 30 days of receiving the complaint.
DURING THE COMPLAINT PROCESS:
The Complainant is encouraged to inquire into the status of the complaint by contacting the President of PMPFIRM at any time.
RESPONSE TO A COMPLAINT:
Once PMPFIRM has reviewed the complaint, PMPFIRM will provide a written response to the Complainant. If the Complainant is dissatisfied with PMPFIRM’s response, the Complainant may ask PMPFIRM to reconsider the response. Such a request should be made in writing and forwarded by mail, email or fax to the address of the President as provided above.
If the Complainant is dissatisfied with the manner in which the complaint has been handled, the Complainant may refer the matter to the following external dispute resolution bodies:
NATIONAL MORTGAGE LICENSING SYSTEM & REGISTRY (NMLS) RESOURCE CENTER
(240) 386-4444 OR www.mortgage.nationwidelicensingsystem.org/contact/Pages/default.aspx
US DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (HUD)
451 7TH ST S.W., WASHINGTON D.C., 20410
PHONE IN D.C. (202) 708-1112 OR www.hud.gov
PMPFIRM’S QUALITY CONTROLS:
Complaints will be continually analyzed by the President promptly upon receipt for the identification of systemic or recurring problems. If such problems are identified, PMPFIRM will consider what actions it may need to take to address these problems. The complaints handling process will be reviewed periodically, and at least annually, to aim to enhance its delivery of efficient outcomes. This review will be performed by the President, Chad F. Olafson, or Elyse Moreton, and PMPFIRM will consider what actions it may need to take to address any deficiencies identified in such a review. Where appropriate, issues that arise as a result of PMPFIRM’s complaints handling process may be incorporated in the process for monitoring and evaluating principal, partner, employee or consultant performance, as applicable.
PLEASE CONTACT CHAD F. OLAFSON IF YOU HAVE ANY COMMENTS OR SUGGESTIONS IN RESPECT TO THE CONTENTS OF THIS POLICY.
THIS PUBLICATION CONTAINS GENERAL INFORMATION ONLY, AND NONE OF PACIFIC MORTGAGE PLANNING LLC ARE, BY MEANS OF THIS PUBLICATION, RENDERING ANY MORTGAGE BROKERAGE, BUSINESS, FINANCIAL, INVESTMENT, LEGAL, TAX, OR OTHER PROFESSIONAL ADVICE OR SERVICES. THIS PUBLICATION IS NOT A SUBSTITUTE FOR SUCH PROFESSIONAL ADVICE OR SERVICES, NOR SHOULD IT BE USED AS A BASIS FOR ANY DECISION OR ACTION THAT MAY AFFECT THE FINANCES OR THE BUSINESS OF ANY COMPLAINANT.
BEFORE MAKING ANY DECISION OR TAKING ANY ACTION THAT MAY AFFECT A COMPLAINANT’S FINANCES OR BUSINESS, THE COMPLAINANT SHOULD CONSULT WITH A QUALIFIED PROFESSIONAL ADVISER. PMPFIRM SHALL NOT BE RESPONSIBLE FOR ANY LOSS WHATSOEVER SUSTAINED BY ANY PERSON WHO RELIES ON THIS PUBLICATION.
PACIFIC MORTGAGE PLANNING LLC IN A NATIONAL MORTGAGE LENDER. WE PROVIDE HOME LOAN SOLUTIONS TO CLIENTS ACROSS THE COUNTRY. FOR THE MOST UPDATED LIST OF STATES WE LEND IN, PLEASE CONTACT ELYSE AT OR CHAD AT
The Gramm-Leach-Bliley Act (the GLB Act) restricts the ways in which financial institutions, including mortgage lenders, may disclose nonpublic consumer information. The Act pertains to two major components of privacy protection: • A financial privacy rule • A safeguards rule
The Safeguards Rule requires financial institutions to develop a written information security plan that describes how the company plans to protect it’s clients’ nonpersonal information.
As a matter of policy, Pacific Mortgage Planning LLC will comply with all aspects of the GLB Act.
2: DISCLOSURE OF POLICY
3: AFFILIATE SHARING OPT-OUT
GRAMM-LEACH-BLILEY ACT - POLICY AND PROCEDURES
4: SAFEGUARDING NONPUBLIC CONSUMER INFORMATION
Pacific Mortgage Planning LLC nonpublic information about consumers from the following sources will be safeguarded: • Information received on loan applications, supporting documentation provided by consumers, and other documents and forms provided by or authorized by consumers. • Information about the consumers transaction with us or others • Information that is received from a consumer credit reporting agency or agencies.
Pacific Mortgage Planning LLC employees will undergo training on GLB ACT requirements and corresponding company policies and procedures. This training, which will first be provided during new employee orientation and then on an on-going basis, will focus on specific precautions such as: • An overview of physical, electronic, and procedural safeguards that Pacific Mortgage Planning LLC adopted to safeguard consumer nonpublic information. • Clean Desk and File Security Policy. Each employee is charged with maintaining a clean desk during business hours and securing files. Employees must clear their desk of the following items at the end of each day or if a client is present: - Putting away non-essential documents and items when hosting a visitor in the work area. - Putting away documents or electronic media containing customer and corporate non-public information whenever there is an extended absence (i.e. lunchtime, breaks, committee meetings, etc.) - Locking computer workstations after 5 minutes of inactivity (TIP: Hit CTRL ALT DEL and then hit ENTER to lock your workstation.) - Refraining from cluttering the workstation with Post-Its or other handwritten notes displaying sensitive information such as user ID’s, passwords, account numbers, etc. - All loan files and papers containing customer and corporate non-public information MUST be locked at the end of each day in drawers or cabinets in addition to your computer being locked. • All emails that contain non-public personal borrower information will be marked as confidential and sent encrypted. Non-public personal information includes items such as borrower financial statements, account numbers, tax returns, social security numbers, credit reports, and any information that should not be in the public realm.