Purpose
Produce a role-based compliance training program for a non-bank mortgage lender — a curriculum map by job function plus ready-to-develop content briefs for each regulatory topic — so training coverage is defensible under a Compliance Management System (CMS) exam and no role is left with gaps. Solves the problem of generic, one-size-fits-all training that regulators flag as insufficient.
When to Use
Invoke this skill when the user asks to:
- Build or refresh an annual compliance training plan
- Create role-specific training for loan officers, processors, underwriters, or servicing staff
- Develop training content briefs for RESPA, TILA, ECOA, BSA/AML, UDAAP, or Fair Lending
- Onboard new hires into a compliance curriculum tied to their role
- Document training coverage for a state exam, CFPB exam, or internal audit
- Map required compliance topics to job functions and determine who needs what
Inputs Required
Before starting, collect:
- Roles to cover: Job functions needing training (e.g., loan officers, processors, underwriters, servicing, management, ops)
- Regulatory topics in scope: Which regs (RESPA, TILA, ECOA, BSA/AML, UDAAP, Fair Lending, HMDA, SAFE Act) — or "recommend based on our roles"
- Company profile: Product lines (purchase, refi, HELOC), states licensed, retail vs. wholesale/broker
- Training frequency: Annual, quarterly, at-onboarding, or event-triggered
- Delivery format: Self-paced e-learning, live/virtual instructor-led, or blended
- Existing training baseline: What's already in place, if anything, and known gaps
- Assessment requirement: Whether completion tracking and knowledge checks are needed for audit purposes
If topics-in-scope is not specified, default to the core five for mortgage lenders (RESPA, TILA, ECOA/Fair Lending, BSA/AML, UDAAP) and note the assumption. If delivery format is unspecified, assume blended.
Instructions
Step 1: Build the Role-to-Topic Coverage Matrix
Map every role to the topics it must receive, at what depth. Not every role needs every reg at the same level.
Use three depth levels:
- Core — full training, tested; the role's work directly triggers this regulation
- Awareness — high-level obligations and escalation path; the role touches it indirectly
- N/A — not applicable to this role's function
Apply these baseline mappings (adjust to the company's roles):
- Loan Officers/MLOs: RESPA (Core — Section 8 referrals/kickbacks), TILA (Core — TRID disclosures, LE timing), ECOA/Fair Lending (Core — steering, adverse action), UDAAP (Core), BSA/AML (Core — customer identification, red flags), SAFE Act (Core)
- Processors: TILA (Core — TRID document accuracy, timing), RESPA (Core — fee tolerances), ECOA (Awareness), BSA/AML (Core — document verification, red flags)
- Underwriters: ECOA/Fair Lending (Core — disparate impact, adverse action reasons), TILA (Awareness), UDAAP (Awareness), BSA/AML (Awareness)
- Servicing: RESPA (Core — servicing rules, error resolution, loss mitigation), TILA (Core — periodic statements), UDAAP (Core — collection practices), ECOA (Awareness)
- Management/Ops: All topics at Core, plus CMS oversight, complaint management, and vendor management
Present the matrix as a table: rows = roles, columns = topics, cells = Core/Awareness/N/A.
Step 2: Sequence the Curriculum
Order the training into a logical learning path per role and across the calendar:
- Onboarding track (day 1–30): Foundational — company CMS overview, ECOA/Fair Lending basics, UDAAP, BSA/AML CIP, role's Core regs at intro depth
- Certification track (before independent work): Full Core-depth modules with assessment
- Annual refresh: All Core topics re-certified; regulatory update module for any rule changes
- Event-triggered: New product launch, new state license, exam finding, or regulatory amendment
Specify estimated seat time per module (typically 20–45 minutes for e-learning, 60–90 for instructor-led).
Step 3: Write a Content Brief for Each Core Topic
For each regulatory topic in scope, produce a content brief a training developer can build from directly. Each brief includes:
- Learning objectives (3–5, action-verb, measurable — "Identify prohibited Section 8 referral arrangements," not "Understand RESPA")
- Key regulatory anchors: Specific provisions and rules to cover (e.g., RESPA Section 8, TRID/12 CFR 1026, ECOA/Reg B adverse action, BSA/AML SAR and CTR obligations) — cite the reg, not just the acronym
- Role-specific scenarios: 2–3 realistic on-the-job situations tailored to the roles receiving this module (e.g., an MLO offered a marketing services agreement; an underwriter deciding whether a co-signer requirement is fairly applied)
- Common violations to teach against: The specific mistakes examiners cite for this reg
- Knowledge check items: 3–4 sample assessment questions with the correct answer and why
- Escalation guidance: Who to notify and how, when the employee is unsure
Step 4: Add the CMS Documentation Layer
Provide the elements that make the program defensible under a CMS exam:
- Training log fields: Employee, role, module, date completed, assessment score, next-due date
- Board/management reporting: What to report up (completion rates, exam findings addressed by training, high-risk role coverage)
- Change management: How to trigger and document training when a regulation changes
- Retention: Recommended record retention period for training records (align to exam lookback expectations)
Output Format
- Structure: Coverage matrix table → curriculum sequence → one content brief per Core topic → CMS documentation layer
- Length: 1,400–2,000 words depending on number of topics
- Format: Table for the matrix; structured sections with numbered briefs; scannable, developer-ready
- Sections: Role-to-Topic Coverage Matrix → Curriculum Sequence → Content Briefs (one per topic) → CMS Documentation Layer
- Tone: Compliance program manager — precise, regulation-anchored, audit-minded; practical enough to hand to a training developer
Quality Checklist
Before delivering output, verify:
- [ ] Every role in scope appears in the coverage matrix with a depth level for each topic
- [ ] Each content brief cites specific regulatory provisions, not just acronyms
- [ ] Learning objectives use measurable action verbs (identify, apply, distinguish) — never "understand" or "know"
- [ ] Each Core topic brief includes at least 2 role-specific scenarios and 3 knowledge check items with answers
- [ ] "Common violations to teach against" reflect actual examiner-cited issues, not generic warnings
- [ ] CMS documentation layer includes training log fields and a record retention recommendation
Notes
- Examiners look for evidence that training is role-appropriate and tied to actual risk — a single generic all-staff course is a common CMS deficiency; the coverage matrix directly counters that finding
- BSA/AML training frequency and content should reflect the lender's AML program risk assessment; annual is the floor, not a ceiling
- When a regulation changes, the change-management trigger should generate a targeted refresh rather than waiting for the annual cycle
- If the company is wholesale/broker, add third-party originator oversight and fair lending monitoring to the management track
How to use this skill
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- Drag this file into a new chat, or copy and paste its contents
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