According to Paul Donahue of Abacus Mortgage Training and Education

Every person in your organization must be held accountable and every organization must create a system of "Responsible Information  Management".  This system must be in use every day and by every employee.  He further states that in order to meet the requirements  every company must:

1. Raise awareness

2. Create Policies and Protections

3. Train Staff

4. Hold all employees and vendors accountable

5. Monitor and retrain employees on policy breaches

6. Actively Protect our Customers

7. Detect Risks

8. Respond to Violations and Breaches

As a CPA and Information Specialist the Developer of LoanMgr has operated his business in compliance with theses laws since 1997.  The Charter Oak Systems Business model is design exactly for the purpose of compliance with the ethical standards of a Certified  Public Accountant and the laws and regulations covering Financial Institutions.

Our Business Operating System covers the requirements of law by separating the functions of a business into the components  necessary for efficient operating controls.  Our policy over the past 10 years has been that an originator cannot have access to our  process software.  Just as we would not give access to our accounting system to all employees mortgage companies cannot give access to processing software to anyone other than a processor, underwriter or closer.

That is why all information is captured and controlled by LoanMgr and information needed to process a loan is transferred by a  processor into the processing software.  The information which is required in loan manager to be accurate is the source of information  used to process a loan.  This provides a fully accountable system in processing a loan.  Every change to important information is  logged dated and stamped on the file. Every discussion, every e-mail sent and every change in status of a loan is fully documented and  retained in a secure environment.