Points of Interest Summer 2019 Page 41 as the DRE then has to subpoena the bank and wait for the copies. (Note: If you have trust accounts, try to get your bank to provide a copy of the signature cards NOW. Don’t wait for an audit and then try to convince them to give them to you in a timely manner.) Thegoodnewshereisthattheaccounting software they are using gives the right reports, the reconciliations are done on a monthly basis (with some changes in how they are done going forward now that the CPA has sat with the auditor for three days and has seen where he was making errors), the signer on the trust accounts is only the broker,theyaregivingtheMLDSandLPDS on all loans and having them personally signed by the borrowers/investors and broker (no electronic signatures), their dba’s are filed correctly, and their agents are properly licensed and have compliant contracts with the broker. Now we finish the exhausting in-office fieldwork with the auditor reviewing files and payoffs (hopefully today is the last day), she writes her report and submits it to her supervisor, and the supervisor decides whether to send it to legal or cite and fine. Now is the waiting period (months, perhaps) to see how the DRE decides to proceed. They will either file an accusation or issue a cite and fine (I’m thinking the latter). I will let you know what happens. Pam Strickland is a compliance consultant who helps brokers prepare for and survive a DRE audit. Call her long before the DRE calls you so you will be prepared. Remember, they can go back three years (usually twelve to eighteen months), so now is the time to get prepared for the future. She can be reached at pam@ pamstrickland.com Stricktly Strickland – continued from page 40