Accounting Letter

Mortgage lenders must integrate four AML program components to meet federal requirements.

Lenders must defer net origination fees over loan life to match income to interest earned.

Ginnie Mae issuers must maintain continuous financial and operational compliance year-round.

Issuers must pass annual audits on finances, controls, and compliance to maintain agency approval.

Fannie Mae and Freddie Mac require annual audits, quarterly reports, and new security attestations.

Auditors must test unobservable assumptions that drive MSR valuations and stress outcomes.

Independent mortgage bankers must satisfy five regulators' audit requirements simultaneously.

Stable rules and recurring errors point to process gaps, not rule confusion.

Multi-state mortgage lenders must navigate separate state and GSE financial thresholds.

How one accounting choice determines every warehouse loan's reporting and control requirements.

ASC 310-20 requires lenders to defer and amortize loan origination fees over the loan's life.