WorkflowLending Compliance & Fair Lending

Loan Compliance Testing

Loan compliance testing on every closed loan, each result tied to the page that proves it

Every rule tested on every loan, each result tied to its page.

See one case, screen by screen ↓
demo1,284loansclosed in August, every one tested — 31,592 rule tests, not a sample
demo41sto test one loan file — 14 documents, 212 pages, 26 rules, each result with its page
demo$38,940of finance charges understated on 7 wholesale loans, traced to one fee-table change
target19daysfrom closing to a confirmed finding, not the next quarterly sample
In short

What is Loan Compliance Testing?

Software that checks closed loans against the consumer-lending rules — APR and finance charge accuracy, TRID timing and tolerance, RESPA, ECOA and flood notices, higher-priced and high-cost tests — and records each result with its evidence. Loan Compliance Testing has agents read the whole file, test every rule that applies and group the fails into findings for the testing manager to confirm.

How to choose AI solutions for lending →

Updated

The problem

Why compliance testing finds the problem a quarter too late

Second-line testers prove, loan by loan, that each closed mortgage met the rules: the APR and finance charge disclosed accurately, the Loan Estimate and Closing Disclosure delivered on time, fee changes inside tolerance, the RESPA, ECOA and flood notices sent, and no higher-priced or high-cost line crossed. By hand, that is a checklist of 40-odd rules per file — so the team pulls a small sample at quarter end and works through it months after the loans closed.

A systemic error does not wait for the sample. One fee code mapped wrong in the loan system keeps producing understated disclosures on every loan it touches, and each month it runs adds borrowers who may need to be re-disclosed or reimbursed. And because the fails are never traced to a branch, channel or system change, the same finding comes back next quarter.

demo64loanstested in last quarter's sample, out of 3,712 closed
demo3findingsback again from last quarter's sample — same rule, same cause, more loans
typical24.7%of critical mortgage QC defects are legal and compliance — the largest category
Where the days go between closing and a confirmed findingestimated
By hand100 days
With the solution19 days
  • Waiting for the loan to be tested55 → 17.5 d
  • Reading the file and ticking the checklist25 → 0.2 d
  • Recomputing the APR and counting business days8 → 0.1 d
  • Grouping fails and finding the root cause7 → 0.2 d
  • Confirming findings and writing the workpaper5 → 1 d

Estimated split: about 100 days for quarterly sample testing by hand; 19 days for the Whitcombe loan in the working solution — closed 14 Aug, F-01 put to the testing manager on 2 Sep.

How it works

How a closed loan is tested

Five specialist agents test every closed loan and recompute every APR; the testing manager confirms each finding.

What comes in
Closed loans in1,284 a month · loan file, loan system, rules, prior findings
Agents at work
File readervalues with pages
Then
Rule selector≈ 25 of 212 rules
Independent calculatorAPR rebuilt
Timing checkerbusiness days
Then
Findings analystrank + root cause
A person decides
Compliance Testing Managerconfirms and signs
What comes out
Result per rule, page cited
Ranked findings
Signed workpaper
One case, step by step

One loan, from closing to a signed finding

Daniel and Rosa Whitcombe closed a $412,000 conventional 30-year fixed purchase through a wholesale broker on 14 August. Here is what the August run found on their loan — and on six others like it — screen by screen, in the working solution.

  1. 0131 Aug 22:00

    Every loan closed in August, tested overnight

    The agents

    The month-end run takes all 1,284 August closings — retail, wholesale and correspondent, in Ohio, Indiana and Kentucky. By 05:52 the wall is full: 31,107 tests pass, 318 fail, 167 need a person, and the fails are already grouped into 8 findings. Last quarter's sample would have looked at 64 loans.

    “7 wholesale loans fail APR and finance charge. Same cause on every one — discount points and lock fees coded seller-paid since the fee-table update of 28 Jul.”

  2. 02Morning

    One loan's test script, every rule with its page

    Graham Feld · Compliance Testing Manager

    Graham opens WH-2026-08-3372. The file reader took 14 documents, 212 pages and the loan system record and pulled 214 values with their page; the rule selector chose 26 of the 212 rules — conventional purchase, first lien, Ohio, closed 14 Aug. The result: 19 pass, 4 fail, 1 review, 2 not applicable, tested in 41 seconds.

    “Disclosed 6.875%, recalculated 7.031% — understated by 0.156, beyond the 0.125% tolerance.” — Closing Disclosure, page 5

  3. 03Rebuilt

    The APR rebuilt from the payment stream

    Independent calculator

    The calculator never takes the disclosed APR as its answer. It classifies every fee on page 2 of the Closing Disclosure as a finance charge or not, rebuilds the amount financed and solves the actuarial APR from 360 payments of $2,638.08. The disclosure counted $10,423.27 of prepaid finance charges; the calculator counts $16,723.27 — the $5,150.00 of discount points and the $1,150.00 rate-lock extension fee were left out.

    Amount financed $395,276.73 · actuarial APR 7.031% · finance charge understated $6,300.00, against a $100 tolerance.

  4. 04Why

    The loan system and the disclosure disagree

    File reader

    The data-integrity test puts the loan system's fee screen beside the Closing Disclosure. Fee codes 802 and 811 — the discount points and the lock extension — are marked “Paid by: Seller” in the loan system, while the Closing Disclosure shows them borrower-paid. That is why the disclosure left them out of the finance charge.

    The loan system's own change log: fee table v14 for wholesale, effective 28 Jul 2026, changed by Pricing Operations.

  5. 05Review

    A result the rules cannot settle, left for a person

    Independent calculator

    One test stays amber: qualified mortgage points and fees. Counting the 1.25 discount points they are 3.54%, over the 3% limit; if the points are bona fide they drop out and it is 2.29%. The undiscounted rate of 6.990% is within one point of APOR at 6.420% — but only the rate sheet can show the points really bought the rate down.

  6. 06Resolved

    The tester decides, with the evidence attached

    Nadia Okonkwo · Compliance tester

    The review goes to a tester. She attaches the wholesale rate sheet of 17 Jun 2026, page 4, which shows the 1.25 points bought the rate from 6.990% to 6.625%, picks “Pass — evidence confirms it” and signs. Had she chosen fail, it would have gone to the testing manager to confirm as a finding.

  7. 0705:52

    318 failed tests, 8 ranked findings

    Findings analyst

    The findings analyst groups the fails by rule and cause and ranks them by severity and loans affected. F-01, APR and finance charge understated, is Critical: 7 loans, 28 failed tests, $38,940 understated, all on the wholesale desk — every affected loan listed with its disclosed and recalculated APR, and a proposed owner, Victor Ames.

    Remediation proposed: correct the fee-table mapping; re-disclose or reimburse the 7 borrowers under the restitution policy; re-test wholesale loans closing in September.

  8. 08Root cause

    Since when, and where

    Findings analyst

    The heat map shows F-01 only in the wholesale column. The change timeline explains it: the rate sheet added a 10-day lock extension on 21 Jul, fee table v14 went live on 28 Jul, the first wholesale lock under it came on 29 Jul, and the 7 affected loans closed between 3 and 22 Aug. Three findings are back from the Q2 sample — F-04, F-06 and F-08 — at a higher count now that every loan is tested.

  9. 09Signed · 2 Sep

    The testing manager confirms the finding

    Graham Feld · Compliance Testing Manager

    Graham checks the evidence — every failed test cites its page and value, the APR and finance charge were recomputed on all 7 loans, the root cause and owner are proposed — and signs. Nineteen days after the Whitcombe loan closed, F-01 goes to the Head of Wholesale Lending, not to the next quarterly sample.

    “Your signature means: I reviewed the evidence and confirm this finding. It goes to the owner and onto workpaper CT-2026-08.”

  10. 10For the exam

    A workpaper written from the run

    Graham Feld · Compliance Testing Manager

    Workpaper CT-2026-08 sets out the objective, the scope — every loan, no sample — the method, results by rule family and the eight findings, prepared by Nadia Okonkwo. Signing it locks it; later changes go in an addendum, and it is kept seven years for audit and the examiners.

Who it’s for

Built for everyone who tests a loan or owns the fix.

The same August run, seen by the four people who carry it — what their quarter looked like, and what it looks like now.

GF
Graham FeldCompliance Testing Manager
Testing manager
Before
“I need the finding in August, not in November.” Learns about a systemic error when the quarterly sample happens to land on it.
Now
Has every closed loan tested within days, confirms each finding with the evidence in front of him, and signs a workpaper written from the run.
NO
Nadia OkonkwoCompliance Tester
Compliance tester
Before
“I test 64 loans and hope the problem isn't in the other 1,220.” Ticks 40-odd rules per file through a sample by hand.
Now
Decides only the results the rules could not settle — with the page, the working and a place to attach the evidence.
VA
Victor AmesHead of Wholesale Lending
Control owner
Before
“Tell me what broke and since when.” Gets a finding months later, with no cause attached.
Now
Gets F-01 with the 7 loans, the dollars understated, the fee-table change that caused it and the date it started.
CN
Celia NavarroFair Lending Officer
Fair lending
Before
“Show me the pattern, not one loan.” Pieces pricing and high-cost results together from sampled files.
Now
Reads every finding by branch and channel or by product, with higher-priced and high-cost tests run on every loan.
Built on the engine

5 agents. Each with one job, and hard limits.

Five specialist agents test every closed loan and recompute every APR; the testing manager confirms each finding.

File reader

Reads the Loan Estimates, Closing Disclosures, note, appraisal receipt, notices, flood determination and the loan system fee screen, and pulls every value the rules need — fees with payer and section, dates of issue, delivery and receipt, rates — with its page and position.

  • Never fills a value it could not find — marks it missing
  • Read-only on the loan system
  • Cites page and position for every value
Rule selector

Chooses which of the 212 rules in the library apply to each loan, by product, lien position, purpose, occupancy, state, channel and application and closing dates.

  • A rule left out always has a reason
  • Library changes need the testing manager
Independent calculator

Recomputes the APR, finance charge, amount financed, total interest percentage, points and fees and rate spread against APOR for the lock week, and the Loan Estimate to Closing Disclosure tolerance buckets — then compares them with the disclosure and shows the working.

  • Never takes the disclosed APR as input
  • Shows the full working on every result
  • Same file, same answer
Timing checker

Counts business days for every delivery and receipt — the specific definition for Closing Disclosure receipt and rescission, the general definition for the Loan Estimate and notices, Sundays and federal holidays excluded.

  • Never assumes receipt without the evidence or the mailbox rule
  • Says when it applied the mailbox rule
Findings analyst

Groups failed tests into findings, ranks them by severity and loans affected, looks for a common branch, channel, product, settlement agent or system change, proposes an owner and drafts the workpaper.

  • Only the testing manager confirms a finding
  • Never contacts a borrower or changes a loan
Compliance Testing Manager

Confirms findings and signs workpapers; testers resolve reviews. The agents propose; a named person decides.

Ask in plain words

Ask about any loan, rule or finding

The testing manager and the testers can ask in plain words — or tell it what to change. Answers point back to the page and the test they came from.

Why did the APR test fail on the Whitcombe loan?

The disclosure counted $10,423.27 of prepaid finance charges and showed an APR of 6.875%. The Closing Disclosure also shows $5,150.00 discount points and a $1,150.00 lock extension fee paid by the borrowers — the loan system has both as seller-paid. Counting them, the amount financed is $395,276.73 and the APR 7.031%: 0.156 over, beyond the 0.125 tolerance. Finance charge understated by $6,300.00.

Which other loans have the same fee-coding problem?

7 loans, all wholesale, all locked after the fee-table update of 28 Jul — Oduya, Tran, Brandt, Lachlan, Whitcombe, Marlow and Verhoeven, closed 3 to 22 Aug. $38,940 in all. No retail or correspondent loan is affected — their fee table did not change.

Test every wholesale loan the day after it closes

Done. From tonight every wholesale loan is tested the night after it closes, on top of the monthly run. Had this been on in August, F-01 would have shown up on 4 Aug, the night after the first affected loan closed — before the other 6. It is in Settings as a watch rule and on the audit trail.

Is the Whitcombe loan still a qualified mortgage?

Probably — a tester needs to confirm one fact. Counting the 1.25 discount points, points and fees are 3.54%, over the 3% limit; if the points are bona fide they drop out and it is 2.29%. The undiscounted rate is 6.990%, within one point of APOR 6.420% — the wholesale rate sheet for 17 Jun will show whether the points really bought the rate down.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

The test runOne loan's test script: the loan, the agents' run log, every rule grouped by regulation with its result, and the page behind the selected test.
The whole monthAll 1,284 August closings on one wall, each loan green, amber or red, with counts by rule family.
The recalculationThe APR rebuilt from the payment stream: every fee classified, the prepaid finance charges, the amount financed and the actuarial APR.
Loan system against the disclosureFee codes 802 and 811 marked seller-paid in the loan system, borrower-paid on the Closing Disclosure.
A review for a personQualified mortgage points and fees at 3.54% with the points, 2.29% if they are bona fide — left for a tester to settle.
Resolving a reviewPass or fail, with the evidence named and a signature.
Every loanFull coverage against last quarter's sample, with pass, fail and review counts and findings for each loan.
Ranked findings318 failed tests grouped into 8 findings by severity and count, each with the affected loans, root cause, remediation and owner.
Confirming a findingThe testing manager signs, and the signature records what it means.
Root causeFindings by branch and channel or by product, the change timeline behind F-01, and what came back from Q2.
The rule library212 rules by family — when each applies, its tolerance, how it is tested, its source and its version.
The testing workpaperObjective, scope, method, results and findings, written from the run and locked once signed.
SettingsPopulation, cadence, rule library, tolerances, who confirms findings and who resolves reviews.
Governance

Built for second-line testing: cited, recomputed, signed.

Every result cites its pageEach pass, fail or review names the page and value it was decided on — Closing Disclosure page 5, Loan Estimate page 1, the loan system fee screen — and the result and page stay on the audit trail.
Recomputed, never read off the disclosureThe APR, finance charge and amount financed are rebuilt from the payment stream and the itemised fees, with the full working shown beside the page, so a fail comes from arithmetic.
Only the testing manager confirms a findingFindings are confirmed with an electronic signature that records its meaning — “I reviewed the evidence and confirm this finding.” Testers sign every review they resolve.
Tolerances go tighter, never looserThe 0.125 APR tolerance from Regulation Z cannot be loosened. Rule versions are dated and approved — library v2026.3, approved 3 Aug 2026 — and every change needs the testing manager.
Agents never touch a loan or a borrowerThe agents read the loan system and never change a loan record or contact a borrower. Remediation goes to the named control owner.
Workpapers locked once signedA signed workpaper is locked and kept seven years. Later changes go in an addendum. Examiners get read-only access to signed workpapers, for 30 days.
Configuration

Your testing program, your settings

What gets tested, how strictly and who decides — set by the testing manager, not built as a project.

SettingDefaultChoose from
Which closed loans are testedEvery closed loanEvery closed loan · 5% random sample · 10% random sample · Risk-weighted sample
When a closed loan is testedNightly, the day after closingNightly · Weekly · Monthly
Rule libraryv2026.3 · 212 rulesv2026.3 · 212 rules, or v2026.2 · 207 rules — a new version is tested on last month first
APR tolerance, regular transaction0.125 percentage pointTighter allowed, never looser than Regulation Z; 0.250 for an irregular transaction
Finance charge tolerance, mortgageUnderstated by no more than $100Set by Regulation Z; a refinance with right to cancel has its own $35 setting
Who confirms findingsGraham Feld · Testing ManagerAny testing manager
Who resolves reviewsCompliance testersCompliance testers · Testing manager only
Keep signed workpapers7 years5 · 7 · 10 years
Connections

Works with the loan files and systems you already have

Loan files and disclosuresLoan Estimates, Closing Disclosures, note, notices, appraisal receipt, flood determination
Your loan origination systemfees, payer, dates and pricing — read only
Rule checklists by product and statefederal rules plus Ohio, Indiana and Kentucky overlays
Rate sheets and APOR tablesfor rate spread and bona fide discount points
Prior testing findingsto show what came back from last quarter
Workpapers and resultsworkpaper PDF and a results workbook for audit and the exam
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of closed loans tested every month, not a 5% sample
1,284 of 1,284 loans
August closings
target
19days
from closing to a confirmed finding, not the next quarterly sample
Quarterly sample≈ 100 days
With agents19 days
typical
24.7%
of critical mortgage QC defects are legal and compliance — the largest category
SampledEvery loan

“demo” = seen in the working solution, on its sample lending data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (ACES Quality Management, Q4 2025 Mortgage QC Industry Trends — 24.66% of critical defects legal, regulatory and compliance). Rules cited: 12 CFR 1026.18, .19, .22, .32, .35, .43 (Regulation Z) · 12 CFR 1024.17, .20 (Regulation X) · 12 CFR 1002.14 (Regulation B). People, lenders, brokers and borrowers named on this page are fictional — characters and sample data in the working solution.

Questions

What compliance teams ask us.

What is loan compliance testing software?

Software that checks closed loans against the consumer-lending rules — APR and finance charge accuracy, TRID timing and tolerance, RESPA, ECOA and flood notices, higher-priced and high-cost tests — and records each result with its evidence. Loan Compliance Testing has agents read the whole file, test every rule that applies and group the fails into findings for the testing manager to confirm.

Does it test every loan or a sample?

Every closed loan, by default — in the working solution, all 1,284 August closings and 31,592 rule tests, against 64 loans in last quarter's sample. A random or risk-weighted sample is still a setting if you want one.

How does it check the APR and finance charge?

It recomputes them. The independent calculator classifies every fee as a finance charge or not, rebuilds the amount financed and solves the actuarial APR from the scheduled payment stream, then compares the result with the disclosure and shows the working. It never takes the disclosed APR as its answer.

How does it count TRID business days?

The timing checker uses the specific business-day definition — all days but Sundays and federal holidays — for Closing Disclosure receipt and rescission, and the general definition for the Loan Estimate and notices. It applies the mailbox rule only when there is no receipt evidence, and says so.

Which rules does it test?

The rules in your library. The working solution runs 212 rules — TILA loan calculations, TRID timing and tolerance, RESPA notices, Equal Credit Opportunity, higher-priced and high-cost, flood, data integrity and Ohio, Indiana and Kentucky overlays — and picks the ones that apply to each loan by product, lien, purpose, state and dates.

Who decides whether a fail is a finding?

People do. Testers resolve every result the rules could not settle, with the evidence attached, and only the testing manager confirms a finding, with an electronic signature. The agents never change a loan record or contact a borrower.

Can we tighten tolerances or add our own rules?

Yes. Tolerances can be set tighter than Regulation Z, never looser, and new rules and rule changes go to the testing manager for approval. A new library version is tested on last month's loans first.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements — your rule checklists, workpaper format and a sample of closed loan files — and it goes live once every quality gate has passed. We will walk you through it on a month of your own closed loans first.

See it on
your closed loans.

We’ll run Loan Compliance Testing on a month of your own closed loans.