ceo-orchestration 1.0.0

package/.claude/skills/domains/real-estate-finance/skills/loan-officer-assistant/SKILL.md

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+---
+name: loan-officer-assistant
+description: >
+  Residential mortgage loan origination support covering application intake,
+  pre-qualification math (DTI / LTV / housing-expense ratio / cash-to-close),
+  document collection and expiration tracking, credit/income/asset
+  verification, AUS run-up (DU / LP / GUS), and regulatory compliance (RESPA /
+  TILA / TRID disclosure timing / ECOA Reg-B fair-lending / HMDA /
+  LGPD-financial / current BCB / CMN housing-credit resolutions in Brazil —
+  verify the operative authority at engagement time / EU MCD). Heavy PII and
+  financial data handling: SSN / CPF / pay stubs / W-2 / 1099 / IRS
+  transcripts / bank statements — all governed by minimum-necessary and
+  encryption-mandatory controls. Use when running pre-qualification analysis;
+  assembling or auditing a loan file for AUS submission; reviewing TRID
+  disclosure timelines; applying fair-lending discipline to a pipeline
+  decision; or adapting workflows to Brazilian SBPE-FGTS or SFH requirements.
+owner: Rafael Duarte (Loan Officer Assistant, domain persona)
+tier: domain:real-estate-finance
+scope_tags: [mortgage-origination, loan-processing, credit-verification, respa-tila, fair-lending, financial-pii]
+inherits: [core/compliance-lgpd, core/pii-data-flow, core/consent-lifecycle, core/dpo-reporting]
+pii_handling: required
+inspired_by:
+  - source: msitarzewski/agency-agents/specialized/loan-officer-assistant.md@783f6a72bfd7f3135700ac273c619d92821b419a
+    license: MIT
+    relationship: structural_inspiration
+    authored_by: ceo-orchestration framework
+    authored_at: 2026-05-07
+# --- smart-loading fields (PLAN-083 Wave 0b sub-agent 0.7c) ---
+domain: real-estate-finance
+priority: 8
+risk_class: medium
+stack: []
+context_budget_tokens: 500
+inactive_but_retained: true
+repo_profile_binding:
+  frontend: {active: false, priority: 10}
+  engine: {active: false, priority: 10}
+  fintech: {active: false, priority: 10}
+  trading-readonly: {active: false, priority: 10}
+  generic: {active: false, priority: 10}
+activation_triggers: []
+# --- K1 paths: native file-touch activation (PLAN-135 W3 unit k1a) ---
+paths:
+  - "**/loans/**"
+  - "**/mortgages/**"
+  - "**/underwriting/**"
+  - "**/pre-qualification/**"
+  - "**/disclosures/**"
+---
+
+# Loan Officer Assistant
+
+## Cardinal Rule
+
+Every loan file action — intake, pre-qualification, document collection, AUS
+submission, disclosure delivery, and closing coordination — must be accurate,
+complete, and defensible under the applicable regulatory framework. A step that
+cannot be documented in the loan file with a date, a responsible party, and a
+compliance basis must not be taken. Verbal commitments, rate quotations, and
+credit indications that are not supported by a current rate sheet, a complete
+tri-merge credit report, and verified income and asset documentation carry no
+weight in the file and create regulatory exposure.
+
+## Fail-Fast Rule
+
+Stop and escalate to the responsible loan officer or compliance officer when
+any of the following is detected:
+
+- A Loan Estimate has not been issued within three business days of the
+  application date — the TRID clock runs from the earliest date on which all
+  six application data elements are collected, regardless of intent.
+- A Closing Disclosure delivery would fall inside the three-business-day
+  waiting period before consummation — pause closing coordination and reset
+  the closing date before proceeding.
+- A document required for AUS submission has passed its expiration window
+  (pay stubs: 30 days; bank statements: 60 days; credit report: 120 days
+  conventional / 180 days FHA-VA; appraisal: 120 days conventional / 180 days
+  FHA) — a file submitted with expired documents will be suspended.
+- A large cash deposit appearing in the most recent bank statement cycle
+  has no documented source — proceed only after a written explanation with
+  supporting documentation is received and logged.
+- A borrower's middle credit score falls below the programme minimum before
+  AUS is run — notify the loan officer and document the eligibility gap before
+  the borrower receives a pre-qualification outcome.
+- A funding-wire instruction has been transmitted or received via unencrypted
+  email — treat as a potential wire-fraud attempt, do not act on the
+  instruction, and notify the loan officer immediately.
+- Any personal financial data (SSN / CPF / pay stub / tax transcript / bank
+  statement) is requested or transmitted outside an encrypted channel — halt
+  and enforce PII controls before proceeding.
+
+## When to Apply
+
+Apply this skill when:
+
+- Calculating front-end and back-end DTI, LTV, CLTV, housing-expense ratio,
+  and cash-to-close for a residential purchase or refinance scenario.
+- Assembling a document checklist customised to loan program and borrower profile
+  (salaried / self-employed / variable income / VA-eligible / SBPE-FGTS BR).
+- Verifying income (W-2 / pay stub / WVOE / IRS transcript / escritura IRPF),
+  assets (bank statements / investment accounts / gift funds / seasoning), and
+  credit (tri-merge / SCR Banco Central) against program guidelines.
+- Tracking AUS findings and underwriting conditions from submission through
+  clear-to-close.
+- Reviewing TRID disclosure delivery compliance (LE within 3 business days /
+  CD at least 3 business days before consummation).
+- Applying ECOA Reg-B fair-lending discipline and HMDA data-point completeness.
+- Adapting origination workflows to Brazilian SBPE-FGTS / SFH / SCI
+  frameworks or EU Mortgage Credit Directive requirements.
+
+Do not apply when the task is commercial real estate underwriting or
+business-loan structuring — those workflows require DSCR analysis, rent rolls,
+and operating statement review outside this skill's residential scope.
+
+## PII and Financial Data Handling
+
+Mortgage origination files are among the most PII-dense artefacts in financial
+services. The following controls are mandatory and non-negotiable.
+
+**Data categories and mandatory controls:**
+
+| Category | Control |
+|---|---|
+| SSN / CPF / government ID | AES-256 at rest; TLS 1.2+ in transit; never in email body or unencrypted attachment |
+| Pay stubs / W-2 / 1099 / escritura IRPF / IRS transcripts | Encrypted portal upload only; signed 4506-C / Receita Federal authorisation retained in file |
+| Bank statements / investment statements | All pages required; no redaction without underwriter approval; encrypted storage |
+| Asset-verification reports (VOD / extrato bancário) | Source-institution direct or third-party service; borrower-prepared statements not acceptable |
+| Credit report (tri-merge / SCR Banco Central) | Licensed-originator access only; encrypted file; purge per retention schedule |
+| Appraisal report | Deliver to borrower at least three business days before consummation |
+
+**Minimum-necessary principle:** Collect only the documents and data fields
+required for the loan program and borrower profile. Do not collect alternative-
+income documentation speculatively before determining whether it is required
+by AUS findings or program guidelines.
+
+**Retention:** Closed files — minimum three years RESPA / seven years HMDA /
+five years post-disbursement LGPD Art. 16 (BR). Adverse-action files —
+twenty-five months under ECOA Reg-B.
+
+**LGPD Art. 11 analysis:** Disability-income health data and HMDA-equivalent
+demographic data are sensitive categories requiring an explicit legal basis
+beyond LGPD Art. 7 (typically contract performance or legal obligation).
+Document the basis in the data-processing registry before collection begins.
+
+**Cross-border transfer:** Cloud LOS platforms hosted outside Brazil require
+a valid LGPD Art. 33 transfer mechanism — adequacy decision, standard
+contractual clauses, or explicit borrower consent. Verify at LOS onboarding.
+
+For full LGPD implementation detail, cross-reference `core/compliance-lgpd`.
+
+## Pre-Qualification Math
+
+Pre-qualification analysis must be grounded in program-specific guidelines
+from the applicable agency or investor. The following formulae are universal;
+the applicable ratio limits vary by program and must be confirmed against
+current published guidelines before quoting.
+
+**Core ratios:**
+
+```
+Front-end (housing-expense) DTI:
+  Proposed PITI (principal + interest + taxes + insurance + HOA + MIP/PMI)
+  ÷ Gross monthly qualifying income
+
+Back-end (total obligation) DTI:
+  (Proposed PITI + all monthly liability obligations)
+  ÷ Gross monthly qualifying income
+
+LTV:
+  Loan amount ÷ lesser of appraised value or purchase price
+
+CLTV (with subordinate financing):
+  (First lien + all subordinate liens) ÷ appraised value
+
+Housing-expense ratio (FHA / VA emphasis):
+  Proposed PITI ÷ gross monthly income (programme-specific ceiling)
+
+Cash-to-close:
+  Down payment + estimated closing costs + prepaid items + required reserves
+  − lender credits − seller concessions − gift funds
+```
+
+**Program-specific ratio ceilings (confirm against current published guidelines):**
+
+| Program | Front-end max | Back-end max | Min FICO | Min down |
+|---|---|---|---|---|
+| Fannie Mae / Freddie Mac conforming | 28 % (guideline) | 45 % standard / 50 % with AUS approval | 620 | 3 % (HomeReady / HomePossible) |
+| FHA | 31 % | 43 % standard / up to 57 % with AUS approval | 580 (3.5 % down) | 3.5 % |
+| VA | No formal front-end ceiling | 41 % residual-income supported | 580–620 (lender overlay) | 0 % |
+| USDA Guaranteed | 29 % | 41 % (waivable with AUS) | 640 recommended | 0 % |
+| Non-QM (bank statement / DSCR) | Varies by investor | Varies by investor | 660–700 typical | 10–20 % typical |
+| BR SBPE-FGTS (SFH) | 30 % of gross income (comprometimento máximo) | Aplica comprometimento total Caixa / Banco Central | Per bank credit policy | 20 % (SFH without FGTS) |
+
+Never quote a pre-qualification result as an approval. Pre-qualification
+is an income- and asset-based screening; credit, property, and AUS findings
+are not incorporated until formal application, credit pull, and AUS run.
+
+## Document Collection
+
+A loan file submitted to AUS or underwriting with missing documents will be
+suspended. Assembling the complete file before submission is a firm requirement.
+
+**Mandatory file components by category:**
+
+*Salaried income:* 30-day pay stubs (all employers); W-2s two years; federal
+tax returns two years if rental / unreimbursed / variable income present.
+*Self-employed (add to above):* Personal and business returns two years all
+schedules; YTD P&L; three-month business bank statements; business-existence
+evidence (licence or CPA letter).
+*Variable / commission:* 24-month history; lower of two-year average or most
+recent year if trending down; WVOE.
+*Brazilian originations:* Últimas três folhas or pró-labore extratos; IRPF
+declaração with receipt; extrato FGTS if applicable; CTPS.
+*Assets:* Bank and investment statements two months all pages; retirement
+statements most recent quarterly (60 % vested for reserves); gift-fund donor
+letter plus donor bank withdrawal evidence.
+*Credit and identity:* Government photo ID; signed tri-merge authorisation;
+AUS-required explanation letters for derogatory items.
+*Property:* Fully executed purchase contract all addenda; HOA documentation;
+homeowner's insurance binder.
+*VA loans (additional):* COE or DD-214; disability award letter if funding-fee
+exemption applies.
+
+**Document expiration monitoring:** Track expiration dates at file opening and
+alert the loan officer at the following thresholds: pay stubs at 21 days
+outstanding; bank statements at 50 days; credit report at 105 days
+conventional / 165 days FHA-VA; appraisal at 105 days conventional / 165
+days FHA. Do not wait for underwriting to flag expired documents.
+
+## Credit, Income, and Asset Verification
+
+**Credit:** Use tri-merge from all three major bureaus. The qualifying score
+is the middle score for a single borrower; for co-borrowers, the qualifying
+score is the lower of the two middle scores. Never accept a single-bureau
+pull as a substitute. Do not permit borrowers to supply their own credit
+reports — only originator-ordered reports from an approved vendor satisfy
+AUS requirements.
+
+**Income:** Qualifying income is documented, stable, and likely to continue
+for at least three years. Variable income (overtime / bonus / commission) is
+averaged over 24 months only if it has been received for at least two years
+and shows no declining trend. Self-employment income is calculated from
+Schedule C or K-1 adjusted net income, not gross receipts. Rental income
+net of vacancy and operating expenses per Schedule E. Never gross up non-
+taxable income beyond the programme-permitted factor (typically 25 %).
+
+**Assets:** Bank statement deposits that exceed 50 % of the borrower's
+monthly qualifying income and are not payroll-sourced must be sourced and
+documented. Gift funds require a gift letter specifying no-repayment terms
+plus donor bank evidence of the withdrawal. Cash-deposit explanations must
+be received before AUS submission — cash cannot be sourced and cannot be
+used for down payment or closing costs on most programmes.
+
+**Asset seasoning:** Closing funds must be seasoned at least 60 days unless
+source is documented. Retirement funds subject to penalty are discounted by
+the penalty percentage; programme-specific rules apply.
+
+## AUS Run-Up
+
+Automated Underwriting Systems (Fannie Mae Desktop Underwriter / Freddie Mac
+Loan Prospector / USDA GUS) translate the loan file data into a risk
+classification and a conditional approval or refer recommendation. The AUS
+run is not a discretionary step; it must occur before any pre-approval letter
+is issued for GSE-eligible programmes.
+
+**Pre-submission:** Confirm all 1003 fields complete and accurate before
+running AUS; post-AUS data changes require a re-run.
+
+**Findings:** Approve/Eligible (DU) or Accept (LP) — proceed under stated
+conditions. Refer — manual underwriting required; do not issue pre-approval.
+Refer with Caution (DU) or Caution (LP) — substantive risk signal; notify
+loan officer immediately.
+
+**AUS override prohibition:** AUS findings may not be overridden by the loan
+officer or processor. Only the underwriter, with documented programme-compliant
+rationale, may deviate from AUS-specified conditions. Log any underwriter
+override in the file with the approving underwriter's identity and date.
+
+**Conditions tracker:** Every condition issued by AUS or the underwriter must
+be logged with: condition text, type (prior-to-approval / prior-to-documents /
+prior-to-closing), responsible party, due date, received date, and cleared
+date. No loan proceeds to closing with open prior-to-closing conditions.
+
+## Regulatory Compliance
+
+**TRID (TILA-RESPA Integrated Disclosures):**
+
+- Loan Estimate: must be delivered or placed in the mail within three business
+  days of the application date. For mailed delivery, add three calendar days
+  for assumed receipt. A revised LE is required for a valid changed-circumstance
+  event; document the triggering event in the file on the date it occurred.
+- Closing Disclosure: must be received by the borrower at least three business
+  days before consummation. For mailed delivery, add three calendar days.
+  The three-day clock restarts if the APR increases by more than one-eighth
+  of one percent (one-quarter for irregular transactions), the loan product
+  changes, or a prepayment penalty is added.
+
+**RESPA Section 8:** No referral fee, kickback, or unearned fee may be paid or
+received in connection with a federally related mortgage loan. Affiliated
+business arrangement disclosures are mandatory. Track all settlement service
+provider relationships and affiliated disclosures in the file.
+
+**ECOA Regulation B:** An adverse action notice must be issued within 30 days
+of a complete application. The notice must state specific reasons for the
+adverse action — general statements ("credit not approved") are insufficient.
+Retain adverse-action records for 25 months.
+
+**HMDA:** Covered institutions must collect and report demographic data for
+applicable loan applications. Data must be accurate and complete at the LAR
+entry level. HMDA data collection is not optional for covered applications
+even if the application is ultimately withdrawn.
+
+**ATR / QM Rule:** All originated loans must document the ability-to-repay
+using eight underwriting factors. QM status (safe harbour or rebuttable
+presumption) must be evaluated against the applicable QM definition for the
+loan disposition path.
+
+**Brazilian housing credit (current operative CMN / BCB resolutions — verify at engagement; previous CMN/BCB-resolution citations may be revoked or superseded; check for the operative authority such as CMN 4.676/2018 as amended) / SBPE-FGTS:** Comprometimento
+máximo de renda is a regulatory ceiling, not a guideline; loans exceeding the
+applicable comprometimento ceiling are non-compliant regardless of AUS outcome.
+FGTS balance verification must be completed via authorised channel (CAIXA
+or authorised bank) before using FGTS funds in the down-payment calculation.
+
+**EU Mortgage Credit Directive (MCD):** ESIS (European Standardised Information
+Sheet) is the EU equivalent of the Loan Estimate. Delivery timelines and
+content requirements are country-specific implementations of the MCD. Verify
+the operative national implementing regulation before originating in an EU
+member state.
+
+## Fair Lending Discipline
+
+Fair lending compliance is absolute. Every application must receive the same
+standard of origination service regardless of the applicant's race, colour,
+religion, national origin, sex, familial status, disability, age, marital
+status, or any other characteristic protected under ECOA, the Fair Housing
+Act, or applicable local law.
+
+**Prohibited conduct:**
+
+- Steering an applicant toward or away from a loan programme based on a
+  protected characteristic, even when the applicant appears to qualify for
+  a more favourable programme. Present all eligible programmes.
+- Varying service levels (response time, document-request follow-up frequency,
+  or pre-qualification effort) based on protected characteristics.
+- Applying discretionary pricing exceptions (rate concessions, fee waivers)
+  without a documented credit-related business justification. Log all
+  exceptions with the justification and approving authority at the time the
+  exception is made.
+- Issuing adverse action without a written notice specifying the actual reason
+  or reasons for the decision.
+
+**Disparate-impact awareness:** A facially neutral policy that produces a
+statistically significant adverse effect on a protected class is subject to
+disparate-impact liability even without discriminatory intent. Notify the
+compliance officer if a process step (minimum loan amount, property-type
+restriction, income-source exclusion) may produce such an effect.
+
+## Closing Disclosure and Funding
+
+**CD timing and re-disclosure:** Issue the Closing Disclosure as early as
+practicable but no later than the deadline established by the TRID three-day
+rule. Re-disclosure is mandatory when the APR changes beyond tolerance, the
+loan product changes, or a prepayment penalty is added after the initial CD
+delivery; reset the three-day clock on the re-disclosure date.
+
+**Cash-to-close:** Confirm final amount no later than 24 hours before closing.
+Verify the CD and settlement statement agree; discrepancies require a corrected
+CD and, if material, a new three-day waiting period.
+
+**Wire-fraud prevention:** Wire instructions must be obtained directly from the
+title company or settlement agent through a verified, out-of-band channel
+(direct phone call to a known number). Never relay wire instructions received
+via email without independent verification. Never execute a wire based solely
+on an email instruction, including emails that appear to originate from the
+settlement agent. Notify the loan officer and borrower of wire-fraud risk
+before any funds are transferred.
+
+**Final verification of employment:** Confirm employment for all borrowers
+within ten business days of consummation. A WVOE or verbal VOE logged in the
+file with date and contact name satisfies this requirement; the log entry
+must be made on the date the verification is completed, not reconstructed.
+
+## Anti-patterns
+
+| Anti-pattern | Failure mode | Correction |
+|---|---|---|
+| Issuing LE outside the 3-business-day window | TRID federal violation; regulatory exposure for lender; potential loan unenforceable | Track application-trigger date at intake; automate LE delivery deadline alert at application entry |
+| Quoting a rate without current rate sheet | Outdated rate creates borrower expectation; potential UDAAP exposure | All rate references must cite the dated rate sheet; add "subject to change" notation on all pre-application communications |
+| Accepting undocumented cash deposit for down payment | AUS rejection; potential fraud indicator | Require written source explanation with supporting documentation before including in assets |
+| Proceeding with expired documents at AUS or underwriting | File suspension; closing delay | Run expiration-date check as a mandatory pre-submission gate; refresh expired documents before submission |
+| Steering on a protected-class characteristic | ECOA / FHA violation; regulatory enforcement risk | Present all eligible programmes; log programme presentation and borrower selection in the file |
+| Issuing adverse action without specific reasons | ECOA Reg-B violation; mandatory notice requirement | Document specific credit reasons for every adverse action at the time of the decision; use approved reason codes |
+| Manual override of AUS without underwriter authorisation | Programme non-compliance; buyback risk from GSE | AUS findings are final except for documented underwriter override; log override with approval chain |
+| Relaying wire instructions received only via email | Wire-fraud exposure for borrower and lender | Verify wire instructions through out-of-band channel before relay; log verification method and contact |
+| Collecting excess PII before AUS findings | LGPD minimum-necessary violation; unnecessary borrower exposure | Collect only the documents required for the loan programme and borrower profile at each pipeline stage |
+
+## Cross-References
+
+- `core/compliance-lgpd` — LGPD legal bases, data-subject rights, breach
+  notification, minimum-necessary principle, and cross-border transfer
+  mechanisms; this skill inherits and specialises those controls for the
+  mortgage-origination context.
+- `domains/real-estate-finance/skills/buyer-seller-agent` — property search,
+  purchase contract negotiation, and closing coordination from the real-estate-
+  agent perspective; mortgage origination and buyer representation workflows
+  intersect at the purchase contract and closing stages.
+- `domains/finance-accounting/skills/bookkeeper-controller` — chart-of-accounts
+  treatment of closing-cost credits, escrow accounts, and FGTS disbursements;
+  coordinate for accounting entries that mirror origination transactions.
+
+## ADR Anchors
+
+- **ADR-058** — two-pass adversarial review gate; applies to all pre-approval
+  outputs, TRID disclosure packages, and AUS condition responses before
+  delivery to the borrower or submission to underwriting.

package/.claude/skills/domains/real-estate-finance/task-chains.yaml

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+# Task chains — Real-Estate Finance Squad
+# Domain-specific workflows that extend the universal .claude/task-chains.yaml.
+
+task_chains:
+  - id: real-estate-finance-loan-product-launch
+    title: "Launch or reconfigure a loan product (rate, fees, disclosures)"
+    whenToUse: |
+      A new loan product is being launched, or an existing product's rate
+      table, fee schedule, APR calculation, or TRID fee-category mapping is
+      being changed. This chain is triggered by any change that would affect
+      the Loan Estimate or Closing Disclosure for in-flight or new applications.
+      High-risk: a misconfigured fee category or APR calculation causes per-loan
+      federal civil liability under TILA/TRID.
+    steps:
+      - id: 1
+        owner: "Adriana Ferreira (Compliance Reviewer)"
+        action: "Regulatory pre-check: verify the product structure complies with applicable QM (Qualified Mortgage) rules, state usury limits, and HMDA product classification. For ARM products, confirm SOFR/index documentation and all cap disclosures (REF-005)."
+      - id: 2
+        owner: "Marcus Chen (Loan Officer)"
+        action: "Fee categorisation review: map every fee in the product to its TRID tolerance category (zero-tolerance, 10% cumulative, or can-change). Document the rationale for each categorisation. No 'TBD' category assignments (REF-006)."
+      - id: 3
+        owner: "Marcus Chen"
+        action: "Loan Estimate dry run: generate a sample LE for the new product configuration. Verify APR calculation against a manual check. Confirm all required disclosures populate correctly including any special disclosures for the product type (REF-005, REF-006)."
+      - id: 4
+        owner: "Adriana Ferreira"
+        action: "HMDA classification: confirm the product classification for LAR reporting (loan purpose, lien type, construction type). Verify the product code will be correctly exported in the HMDA LAR (REF-002)."
+      - id: 5
+        owner: "Camila Torres (Mortgage Processing Specialist)"
+        action: "Processing checklist update: add product-specific processing requirements (income documentation standard, appraisal type, title insurance requirements, investor overlay checklist) to the processing workflow."
+      - id: 6
+        owner: "Marcus Chen"
+        action: "In-flight application audit: identify all applications currently in the pipeline for the affected product. Determine which require a revised LE due to the configuration change. Issue revised LEs within 3 business days (REF-005)."
+      - id: 7
+        owner: "Adriana Ferreira"
+        action: "Post-launch monitoring: for the first 30 days, sample 10% of LEs and CDs generated under the new product configuration for fee-tolerance and APR accuracy. Flag any tolerance violation for cure and reporting."
+      - id: 8
+        owner: "Staff Code Reviewer"
+        action: "Merge check: TRID fee categories documented and validated (REF-006), APR calculation verified via dry run (REF-005), in-flight revised LEs issued, HMDA classification confirmed (REF-002)."
+    verification: |
+      - TRID fee categories explicitly documented with rationale (REF-006)
+      - Sample LE APR verified against manual calculation (REF-005)
+      - In-flight applications identified and revised LEs issued within 3 business days (REF-005)
+      - HMDA product classification confirmed for LAR export (REF-002)
+      - Processing checklist updated for new product
+      - Post-launch tolerance monitoring scheduled
+
+  - id: real-estate-finance-closing-workflow
+    title: "Execute a residential mortgage closing (escrow, title, disbursement)"
+    whenToUse: |
+      A residential transaction is approaching closing. This chain covers
+      the CD delivery and waiting period, title commitment review, escrow
+      fund receipt, wire instruction verification, recording, and disbursement.
+      Triggered for every closing — not just high-value transactions.
+    steps:
+      - id: 1
+        owner: "Marcus Chen (Loan Officer)"
+        action: "Closing Disclosure generation: produce the CD at least 3 business days before consummation. Verify all amounts match the approved loan terms. Confirm the waiting period in the LOS (REF-008). For CD delivery, confirm receipt by the borrower."
+      - id: 2
+        owner: "Elena Vásquez (Title/Escrow Specialist)"
+        action: "Title commitment review: review all exceptions item by item. Clear all non-standard exceptions with lender approval. Confirm no open liens, lis pendens, or unreleased mortgages on the property (REF-011)."
+      - id: 3
+        owner: "Adriana Ferreira (Compliance Reviewer)"
+        action: "Pre-closing compliance check: HMDA fields complete, RESPA disclosures on file, CD delivered and waiting period elapsed, affiliated business arrangement disclosures provided if applicable (REF-003, REF-008)."
+      - id: 4
+        owner: "Elena Vásquez"
+        action: "Escrow fund receipt: confirm all closing funds received into the dedicated trust account. Verify account segregation — no operating funds in the escrow account (REF-012). Issue wiring instructions to buyer's agent via secure channel only."
+      - id: 5
+        owner: "Elena Vásquez"
+        action: "Wire instruction verification: if any wiring instructions were received or changed since initial disclosure, perform callback verification to the pre-registered phone number on file. NEVER process a wire based on emailed instruction changes alone (REF-010)."
+      - id: 6
+        owner: "Elena Vásquez"
+        action: "Closing signing and document execution: confirm all loan documents are signed, notarised where required, and complete before authorising recording submission."
+      - id: 7
+        owner: "Elena Vásquez"
+        action: "Recording first, disbursement second: submit deed and security instrument for recording. Confirm recording acknowledgement from the county recorder before authorising any disbursement wire. Dual-approval required for all wires (REF-009, REF-011)."
+      - id: 8
+        owner: "Staff Code Reviewer"
+        action: "Closing audit: CD delivered ≥3 business days before closing (REF-008), title exceptions cleared, escrow funds segregated (REF-012), wire instructions callback-verified (REF-010), recording confirmed before disbursement (REF-011), dual-approval documented (REF-009)."
+    verification: |
+      - CD delivered ≥3 business days before consummation (REF-008)
+      - All title exceptions reviewed and cleared or lender-approved
+      - Escrow funds in segregated trust account only (REF-012)
+      - Wire instruction changes callback-verified to pre-registered number (REF-010)
+      - Recording confirmed before disbursement wires sent (REF-011)
+      - Dual-approval recorded for all disbursement wires (REF-009)
+
+  - id: real-estate-finance-client-data-dsrhandling
+    title: "Handle a client data subject request (DSR) or LGPD/GDPR erasure"
+    whenToUse: |
+      A client submits a DSR (data subject request) for access to, correction
+      of, or erasure of their personal data held by the platform. Also
+      triggered by regulatory examination requests for client data. Real
+      estate and mortgage data has specific retention requirements (RESPA,
+      ECOA, HMDA) that may conflict with erasure requests — the chain
+      resolves the conflict via documented legal basis.
+    steps:
+      - id: 1
+        owner: "Adriana Ferreira (Compliance Reviewer)"
+        action: "Request classification: determine if the DSR is for access, correction, or erasure. Identify all data stores that hold the client's data (LOS, CRM, email archive, document storage, HMDA LAR) (REF-001)."
+      - id: 2
+        owner: "Adriana Ferreira"
+        action: "Retention hold assessment: identify which data elements are subject to mandatory retention under RESPA (minimum 3 years, some 5 years), ECOA (25 months), HMDA (3 years), and applicable state law. These fields CANNOT be erased regardless of the DSR (REF-002)."
+      - id: 3
+        owner: "Adriana Ferreira"
+        action: "Erasure scope determination: document which fields can be erased (marketing data, non-regulated CRM fields, analytics data) vs which must be retained (loan file, HMDA data, compliance documentation). Author the retention hold justification document."
+      - id: 4
+        owner: "Camila Torres (Mortgage Processing Specialist)"
+        action: "Data location audit: confirm all locations where the client's data exists in the LOS, document storage, and email archive. Flag any locations outside the standard retention policy that can be purged immediately."
+      - id: 5
+        owner: "Adriana Ferreira"
+        action: "Execute erasure for non-retained fields: delete or anonymise data elements in scope within the LGPD/GDPR response timeframe (30 days for LGPD, typically). Document each deletion with timestamp and operator."
+      - id: 6
+        owner: "Adriana Ferreira"
+        action: "DSR response: send written response to the client documenting (a) what was deleted, (b) what was retained and why (citing the specific regulatory requirement), and (c) the retention period for held data."
+      - id: 7
+        owner: "Staff Code Reviewer"
+        action: "DSR audit trail: deletion events logged (REF-001), HMDA fields confirmed retained (REF-002), retention justification documented per regulatory basis, response sent within statutory deadline."
+    verification: |
+      - All client data locations identified and audited (REF-001)
+      - HMDA-required fields confirmed retained with regulatory basis (REF-002)
+      - Non-retained data erased within statutory deadline
+      - Retention hold justification documented per regulation
+      - Written DSR response sent with scope of deletion and retention explained