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John Levonick
Chief Executive Officer at Canopy Financial Technology Partners
John Levonick is a seasoned professional with a diverse background in consumer finance, FinTech, blockchain, and digital assets. He is the Chief Executive Officer at Canopy and has previously served as a Member Of The Board Of Advisors at elphi. John has also been a part of the Legal Working Group at Wall Street Blockchain Alliance. He holds a degree from UMLaw and is known for his expertise in RegTech. John's entrepreneurial spirit and leadership skills have made him a prominent figure in the industry.
Highlights
⭐ ATTN: Mortgage Originators or Secondary Market Issuers that wish to use AVMs for credit decisions or securitization determinations...
🏛 The OCC, Board, FDIC, NCUA, CFPB, and FHFA (collectively, the agencies) issue a Final Rule dated 08/07/24, with an Effective Date 10/01/2025.
✅ The agencies are adopting a final rule to implement the quality control standards mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) for the use of automated valuation models (AVMs) by mortgage originators and secondary market issuers in determining the collateral worth of a mortgage secured by a consumer's principal dwelling. Under the final rule, institutions that engage in certain credit decisions or securitization determinations must adopt policies, practices, procedures, and control systems to ensure that AVMs used in these transactions to determine the value of mortgage collateral adhere to quality control standards designed to ensure a high level of confidence in the estimates produced by AVMs; protect against the manipulation of data; seek to avoid conflicts of interest; require random sample testing and reviews; and comply with applicable nondiscrimination laws.
🐝 Mortgage originators and secondary market issuers that engage in credit decisions or covered securitization determinations themselves, or through or in cooperation with a third-party or affiliate, must adopt and maintain policies, practices, procedures, and control systems to ensure that automated valuation models used in these transactions adhere to quality control standards designed to: (a) Ensure a high level of confidence in the estimates produced; (b) Protect against the manipulation of data; (c) Seek to avoid conflicts of interest; (d) Require random sample testing and reviews; and (e) Comply with applicable nondiscrimination laws.
CFPB [Regulation Z]; FHFA [12 CFR part 1222]; OCC [12 CFR Chapter I]; Federal Reserve [Regulation Y]; FDIC [12 CFR part 323]; NCUA [12 CFR Part 722 and Part 741] plus for entities that are not covered by any of the above, do not fear, State Attorneys General have enforcement authority.
🔥 OF NOTE : The oversight authority that these amendments to TILA/Reg Z give to the CFPB, as it applies specifically to Secondary Market Issuers, when you take into account the decision in the U.S. Court of Appeals for the Third Circuit in CFPB v. National Collegiate Master Student Loan Trust makes it abundantly clear that the CFPB is going to be actively involved in oversight of non-bank Secondary Market Issuers.
🤷♂️ Quis custodiet ipsos custodes?
https://lnkd.in/ewjJM4q9
Cybersecurity in mortgage lending is confusing... this article is a good example.
Cybersecurity and data privacy audits must be tailored to the regulatory obligations of the subject organization, using the appropriate reference framework, and conducted with absolute precision.
While financial institutions have express security and privacy regulatory compliance obligations, they also have third-party risk management obligations over their vendors that process and hold their consumer data. Thus different frameworks are appropriate for these different entities.
A FI's security and privacy requirements are different than that of their vendor whom are subject to third-party risk management oversight by the FI. Frameworks are specific and they are not all the same, as inferred by this article … here are the top two, one for financial institutions and the other for critical third-party service providers.
FI's should track to the NIST CSF 2.0 framework, as it outlines 6 key core functions: Identify, Protect, Detect, Respond, Recover and Govern. NIST has become the gold standard for assessing cybersecurity maturity, identifying security gaps, and meeting cybersecurity regulations.
SOC2 is a trust-based cybersecurity framework and auditing standard developed by the American Institute of Certified Public Accountants (AICPA) to help verify that vendors (third-party risk) are securely managing client data with five primary trust principles: Security, Availability, Processing Integrity, Confidentiality and Privacy.
A SOC2+ is a customized version of SOC2 that includes additional criteria for industry specific standards, such as the regulatory compliance obligations that FI's are subject to. The SOC2+ should be the goal for third-party service organizations that support FI clients, process consumer data, and store that consumer data, to add the NIST CSF principles on top of the five primary trust principles of SOC2.
A cybersecurity audit is vital and it may trigger time sensitive remediation issues that must be immediately address once identified. We manage cybersecurity audits with technical assistance from our trusted information security professionals (non-attorneys) that we oversee as part of our audit. Our role is to identify gaps between the relevant framework and the client's actual infrastructure controls/governance, to offer guidance on any risk mitigation issues, oversee third-party infrastructure remediation efforts, and provide guidance on if and how the infrastructure not only fulfills the obligations of the framework, but how the infrastructure meets strict federal and state regulatory obligations depending on the FI’s charter or state license footprint.
Cybersecurity and data privacy audits require precision and regulatory compliance/legal guidance. It is complex and it is certainly not something that you leave to an unknown random third-party... trust is key!
#Cybersecurity #Mortgage #FinTech #MortgageTech #GRC #FederatedSecOps
