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HMPL Error Correction

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We found an HPML in our audit. There is no escrow set up. What can we do?

From an auditing perspective you realize that you have a problem. You can’t “undo” the problem, but you can make it as “right” as possible, by establishing the escrow account and looking for the root cause of the problem and trying to eliminate that. You may still be criticized but you will have done all that can be done. And you will have demonstrated the effectiveness of your compliance program.
Learn more about Andy Zavoina’s Escrow Rules

First published on 10/24/2021

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