Commercial in confidence
System Review Report
MortgageManager commission trail system
Independent technical, data and security review
Attention Chris Staats
Prepared by MDS Diversified
Date 29 July 2026
3/10vs 2026 market standard
The system has run the trail book every month since 2003 and its core arithmetic is accurate,
but the review found material financial exposures, confirmed software defects, and no modern
security controls. Full detail in the report below.
Five headline findings
- A single mis-keyed $903 million loan has generated $13.17 million of fictitious trail — 56% of all commission the system has ever calculated.
- 53 loans are configured to distribute 199% of the trail received: ~$259,600 cumulative excess since 2006, still occurring monthly.
- $436,145 of trail actually paid by lenders was never matched to a loan, so no split or remittance was produced for it.
- The engine never retires a loan, so ~44% of the current book is phantom records accruing negative commission.
- No password, no user accounts, no audit trail, and broker/agent bank details stored in plain text.