| from: | Anoop Bungay <anoop.bungay@mortgagequote.ca> |
| to: | jeremy.rudin@osfi-bsif.gc.ca |
| date: | Aug 8, 2016, 12:19 AM |
| subject: | A Canadian Technology First: ISO 9001:2015-Certified Quality Management Systems for Residential Mortgage Underwriting & Credit Intermediation |
| mailed-by: | mortgagequote.ca |
: | Important according to Google magic. |
Jeremy Rudin
Superintendent:
Office of the Superintendent of Financial Institutions
13th Flr., Kent Sq., 255 Albert St.
Ottawa, Ontario K1A 0H2
Phone: 613-990-3667
Fax: 613-993-6782
Mr. Rudin,
My name is Anoop Bungay and I am President of MortgageQuote Canada Corp. Since 2008, our firm has had the privilege of being Canada's first and only ISO 9000 certified credit intermediary. You will be pleased to learn that as of June 16, 2016, MortgageQuote Canada Corp. became the world's first credit intermediary whose Quality Management System complies with the requirements of ISO 9001:2015 for the following scope: Provision of mortgage banking and mortgage brokerage services. Please see our ISO 9001:2015 Certificate, attached. To further our bona fides: since 2008, British Standards Institute (BSI Global) is both our ISO certification body and our external auditors.
Respecting your letter to All Federally Regulated Financial Institutions on July 7, 2016; you are correct - Canadian financial Institutions need improved (and effective) systems that ensure regulatory compliance is maintained when it comes to Residential Mortgage Underwriting Practices and Procedures. Creating a regulatory compliant and functional mortgage underwriting and management system to reduce risk and manage uncertainty was my vision, over 10 years ago and implementation and certification to ISO 9001:2015, is how we achieved it. We were lucky to have earned our first ISO 9001:2000 certification in 2008, just as our peers were being negatively affected by the "great credit crisis".
After nine years of continuous certification, through three revisions of increasingly rigorous quality management standards (ISO 9001:2000, ISO 9001:2008 and ISO 9001:2015), MortgageQuote Canada Corp. has not only mastered the process of regulatory compliant residential mortgage underwriting, we have developed a very stable integrated management and operating system which ensures that all departments of a credit intermediary are effective, efficient and regulatory compliant, including: Origination, Underwriting, Funding, Enforcement, Compliance, Audit, Management & Reporting. The real benefit of certification to ISO 9001:2015 is that our business processes are audited twice a year by third-parties, which ensures that we are continually using our system - daily for each and every transaction - and not just once-in-a-while.
The MortgageQuote Quality Management System has successfully passed the test of litigation. Strict adherence to our ISO 9001:2015 based mortgage underwriting processes and related internal controls, enabled us to prove beyond any doubt, that all regulatory compliant requirements were fulfilled and any claim against our company was without merit. Success in matters of litigation has enabled MortgageQuote to earn the right to act as expert witness for some law societies in Canada, in defense of some of their members, in matters of claims-of-negligence pertaining to mortgage transactions.
While MortgageQuote Canada Corp. is the only credit intermediary in Canada with ISO 9001:2015 certification for it's end-to-end processes including residential mortgage underwriting, in 2014, the Bank of Canada had some departments with ISO 9000 certification (proof (#1 in Canada for Quality Management: Best-in-Industry Sector & Best-in-Industry Class: World's First
)). One chartered bank, CIBC had implemented an ISO 9000 quality management program for their telephone banking department but did not certify their mortgage underwriting operations (proof (#1 in Canada for Quality Management: Best-in-Industry Sector & Best-in-Industry Class: World's First)).
Earlier this year, I decided it was important to share our Canadian regulatory compliant mortgage processing technology with the world by marketing our ISO 9001:2015 certified Quality Management Systems and expertise to governments, banks and credit intermediaries, globally. We started in Switzerland, where the World Economic Forum (WEF) is based because each year the WEF painstakingly ranks each country for Trust & Confidence in the Banking Sector. My thinking was "if the WEF painstakingly ranks countries by trustworthiness and confidence in banking (credit intermediation subsector) each and every year, then the members of WEF might be interested in what MortgageQuote has done by marrying ISO 9001:2015 to the credit intermediation industry". Perhaps some members of the WEF would be interested in transferring our Canadian regulatory compliance technology for the finance sector into their respective jurisdictions. After over 25 years of history, ISO 9001:2015 is proven to be a perfect instrument for technology transfer because it is designed to be scalable and transferable across multiple jurisdictions and technology platforms.
When I read the contents of your letter dated July 7, it dawned on me, rather than going international, why not help the members of the finance sector in our own country? Especially if the Superintendent deems it to be worthwhile.
Without naming names, as you are already aware, there are a number of Canadian mortgage lenders who, if they knew MortgageQuote Canada Corp. existed, would have saved themselves from being exposed to risk caused by poorly originated mortgage transactions by using our systems. In the absence of effective management systems, operating processes and internal controls, trust and confidence cannot be maintained.
Within an OSFI context, our MortgageQuote regulatory compliance technology helps the Canadian mortgage industry as follows:
- OSFI expects mortgage lenders to verify that their mortgage operations are well supported by prudent underwriting practices, as well as sound risk management and internal controls that are commensurate with these operations.
MortgageQuote meets this requirement within its ISO 9001:2015 certified Quality Management System.
- “OSFI wants to see sound mortgage underwriting procedures in place that adapt to the ever-changing circumstances in this area”.
MortgageQuote meets this requirement within its ISO 9001:2015 certified Quality Management System; our mortgage underwriting standards are based upon the Internationally Generally Accepted Mortgage Underwriting Standards (
GAMUS.org).
- OSFI will be placing a greater emphasis on confirming that controls and risk mitigating practices at mortgage lenders and mortgage insurers are sound and consistent with the principles underpinned by OSFI Guideline B-20 — Residential Mortgage Underwriting Practices and Procedures and OSFI Guideline B-21 — Residential Mortgage Insurance Underwriting Practices and Procedures.
MortgageQuote meets this requirement within its ISO 9001:2015 certified Quality Management System
MortgageQuote Canada Corp. has proven to the world that benefiting from the principles of quality management (zero defects, customer satisfaction and regulatory compliance) is not limited to manufacturing and distribution companies. Over 9 years of continuous ISO 9000 certification has enabled MortgageQuote to fine tune it's processes and create an efficient system that is functional, cost effective and scalable from 1 employee to 100,000+ employees. We are a template of leadership in Canada and in an effort to help you achieve your goals, would appreciate the opportunity to amplify this message to the other industry members in Canada - whether they are a Federally Regulated Chartered Bank, Mortgage Investment Company, Mortgage Brokerage firm, Private Lender, Peer-to-Peer Lender - or to the general public.
It would be a privilege clarify how OSFI might be able to leverage MortgageQuote's ISO 9001:2015 regulatory compliant mortgage underwriting technology, in an effort to help strengthen Canada's financial sector.
Anoop Bungay
-- If you have questions, please contact me at your convenience. In order to prevent errors and omissions, email is the preferred choice of communication.
Thank you for choosing MortgageQuote Canada Corp., 'Proud sponsor of the Canadian dream.'®
Sincerely yours,
A. K. (Anoop) Bungay, B. Comm., AMP
Broker
MortgageQuote Canada Corp.
Alberta (AB) * British Columbia (BC) * Ontario (ON)
ON Brokerage License #12279
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