Terms and Conditions: RatePlug Vendor - Use Procedures

1. 1. Periodic Updating of Rate Scenarios; periodically but no less frequently than once every five-business days:
      1. Branch Manager runs Optimal Blue pricing scenarios that can be used to populate the pricing scenario matrix in Rate Plug (“RP”).
      2. The Optimal Blue scenario output is printed electronically and saved in a secure, share drive and is accessible for audit
      3. Branch Manager or a designated, non-originating employee then uses the Optimal Blue scenario outputs populates the RP scenario grid with appropriate rates.
         1. The Branch Manager or a designated, non-originating employee takes a print screen of the RP rate grid and saves it in the same folder as the Optimal Blue scenario output print screens. Folders to be organized by date.
         2. LOs cannot access and update the RP rate grid.
   2. Periodic Updating of Fees; periodically but no less frequently than once a month:
      1. Branch Manager or a designated, non-originating employee:
         1. Completes a sample Loan Estimate (LE) and saves a copy of it.
         2. Populates the appropriate fee matrices in RP using the generated Loan Estimate (LE).
         3. Takes a print screen of the RP fee matrices and saves the print screen together with the sample Loan Estimate (LE) in a secure, share drive location. Folders to be organized by date.
   3. Periodic Audit Procedures at least quarterly:
      1. Generate the system-generated, independent report from RP of all the flyers that have been generated in the system.
      2. Select a random sample of the flyers using a statistically meaningful sample size but no less than 30.
      3. For each item in the sample selection:
         1. Identify the appropriate update date for the rate matrix in RP, which will be based on the date of the flyer. The date will be within the preceding 5 business days of the flyer.
         2. Locate the folder in the secure, share drive facility that corresponds with the appropriate rate update date.
         3. Match the rate information in the flyer with the saved Optimal Blue output print out.
         4. Pass if information matches and Fail if Optimal Blue backup is missing or the rates don’t match.
      4. For each item in the sample selection:
         1. Identify the appropriate update date for the fee matrix in RP, which will be based on the date of the flyer. The date will be within the preceding 30 business days of the flyer.
         2. Locate the folder in the secure, share drive facility that corresponds with the appropriate fee update date.
         3. Ensure that the fees entered in the RP system as evidenced by the print screen of the RP fee matrix input screen matches the fee information captured in the sample Loan Estimate (LE).
         4. Pass if information matches and Fail if either the RP screen print or the sample Loan Estimate (LE) is missing or the fees don’t match.

Comments From Jonathan Gwin:
The above procedure will help ensure that there is a process for saving the backup of Optimal Blue rate and fee scenarios. This can be easily auditable. RP produces an unbiased report of the universe of all the flyers printed. This universe can easily be audited against what the Branches actually did.