This review generally focuses on key consumer compliance regulations covering loan disclosures and terms, underwriting, appraisals, loan originator compensation, and loan closing. Generally, samples of each type of open-end and closed-end consumer credit offered by your institution will be reviewed for compliance with applicable regulations including originated and non-originated applications and will include a review of the Bank’s compliance management program as it relates to loan origination. The review will include various lending channels including retail, mortgage department, and indirect lending if applicable. A small sample of business loans will also be reviewed for their compliance with the Flood Insurance, HMDA, and ECOA regulations.
Training sessions will be provided during each visit to loan officers and support staff responsible for the completion of all loan-related documents. Training is typically held at the conclusion of the review and will focus foremost on deficiencies uncovered during the review. Training sessions will include information regarding new lending-related regulations and/or upcoming regulatory changes. Handouts or Power Point presentations will be utilized to provide summary comments relative to the areas covered during training.
Generally, the review will include the following requirements as related to loan origination:
Training sessions will be provided during each visit to loan officers and support staff responsible for the completion of all loan-related documents. Training is typically held at the conclusion of the review and will focus foremost on deficiencies uncovered during the review. Training sessions will include information regarding new lending-related regulations and/or upcoming regulatory changes. Handouts or Power Point presentations will be utilized to provide summary comments relative to the areas covered during training.
Generally, the review will include the following requirements as related to loan origination:
- Truth in Lending
- Consumer Leasing
- Fair Credit Reporting
- FCRA, Section 609(g) – Disclosure of Credit Scores by Certain Mortgage Lenders
- FCRA, Sections 615(a) and (b) – Adverse Action Disclosures
- FCRA, Section 615(h) and Regulation V Subpart H – Duties of Users Regarding Risk-based Pricing
- Real Estate Settlement Procedures
- Flood Insurance
- Homeowners Protection Act
- Preservation of Consumer Claims and Defenses
- Equal Credit Opportunity
- Home Mortgage Disclosure
- Credit Practices Rule
- Consumer Protection in Sales of Insurance
- E-Sign Act