Octopus Financial Group LLC

Jorge Ruiz, Mortgage Loan Originator (MLO)

1. Purpose of the Plan

The purpose of the Quality Control Plan (QCP) for Octopus Financial Group LLC is to ensure the integrity, accuracy, and regulatory compliance of all mortgage loan origination activities. This plan aims to minimize risks, prevent fraud, and protect the interests of clients and financial institution partners.

2. Scope

This QCP applies to all activities related to mortgage loan origination, including:

- Initial application review.

- Client disclosures.

- Loan processing, underwriting, and closing.

- Post-closing management.

3. Responsibility

The implementation and oversight of this QCP is the responsibility of Jorge Ruiz, who serves as the sole Mortgage Loan Originator (MLO) for the company.

4. Quality Control Procedures

4.1 Compliance Verification

- Ensure every loan complies with federal regulations, including TILA, RESPA, ECOA, and HMDA, as well as applicable state regulations.

- Confirm that initial and final disclosures are delivered within the required timeframes.

- Verify that all required documents are complete and properly executed.

4.2 Fraud Prevention

- Perform cross-checks on client information using data validation services, such as employment, income, and asset verification.

- Use technology tools to detect fraud indicators in loan applications.

4.3 Internal Audits

- Review at least 10% of loans originated each month to identify errors or inconsistencies.

- Randomly select loans, including those with higher risk characteristics, for evaluation.

4.4 Documentation

- Maintain a complete file of all loan-related documents for a minimum of 5 years or as required by applicable regulations.

- Record any compliance findings and document corrective actions taken.

5. Training

Jorge Ruiz will participate in regular training to stay updated on:

- Changes in mortgage lending laws and regulations.

- Fraud prevention techniques and industry best practices.

6. Corrective Action Procedures

- If an error or compliance issue is identified, Jorge Ruiz will develop a corrective action plan within 7 business days.

- Recurring issues will be documented, and procedures will be adjusted to prevent future occurrences.

7. Reporting

- Prepare a quarterly report summarizing the results of internal audits and significant findings.

- Submit reports to regulatory entities as required.

8. Review Frequency

This plan will be reviewed and updated annually or as needed to reflect changes in regulations or operations at Octopus Financial Group LLC.

9. Record Management

All documents related to the Quality Control Plan and originated loans will be securely stored in a system that complies with data protection regulations (e.g., encryption and restricted access).