--- name: compliance-training-program-builder description: "Generates role-specific compliance training outlines and content briefs for non-bank mortgage lenders covering RESPA, TILA, ECOA, BSA/AML, UDAAP, and Fair Lending — mapped to job roles, sequenced into a curriculum, and aligned with CMS training program expectations. Use when building or refreshing an annual compliance training plan, onboarding new hires into a role-based curriculum, documenting training for an exam or audit, or creating content briefs for specific regulatory topics." argument-hint: "[roles] [regulatory-topics]" allowed-tools: ["Read"] --- # Compliance Training Program Builder ## 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: 1. **Learning objectives** (3–5, action-verb, measurable — "Identify prohibited Section 8 referral arrangements," not "Understand RESPA") 2. **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 3. **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) 4. **Common violations to teach against**: The specific mistakes examiners cite for this reg 5. **Knowledge check items**: 3–4 sample assessment questions with the correct answer and why 6. **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 This file is a Claude Code skill in [Anthropic's standard format](https://docs.anthropic.com/en/docs/claude-code/skills) — markdown with YAML frontmatter at the top. **Installing in Claude Code:** - `~/.claude/skills//SKILL.md` — auto-loads in every session anywhere on your machine (recommended for skills you'll use across multiple projects) - `/.claude/skills//SKILL.md` — auto-loads only when working in that project (recommended for project-specific skills) Restart Claude Code or open a new session to register. **Using in Claude.ai, ChatGPT, Gemini, or other AI tools:** 1. 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