Compliance Huddle April 2017

Recent Exams Does anyone currently have examiners on-site? Is there still a continuing increase in request information? What is the focus of the on-site? Has anyone just been through an exam or recently received their ROE? Has examiner “tone” changed from the last on-site? Are the reports giving credit where credit is due, or if there were concerns, are the reports written in such a way that the regulators are seemingly sympathetic or more demanding? What are some of the areas of focus?

Agenda Exams/Audits Findings HMDA Beneficial Ownership Credit Reporting Changes Mortgages in General Questions from your peers Anything else on your mind

HMDA How is your bank preparing for the new data submissions? Do you have the resources to handle the expanded reporting requirements? Are you working with software providers? Who has got the system updated and ready to at a minimum test the platform? How is the testing going Policies updated, started training of responsible staff? Budget: how much is this going to cost? Any other concerns?

Beneficial Ownership System updates? Training? Procedures? Policy updated?

Credit Reporting Changes Started talking about how this might effect underwriting? Loan analysis criteria updates? Included in the topic of discussion – automatic underwriting and decisioning software?

Mortgage Loans in General TRID – recent violations in transaction testing from monitoring, audits or exams Zillow – paid leads Change in circumstance for LE and CD

Questions for the Group from Peers CRA data integrity exams – what all is involved? What are auditors and in-house monitoring looking at for RESPA? What is the group’s take on successor in interest, and for those who have dealt with these situations, please share your process. Are any of our banks beginning to work on storing data for CECL requirements? If so, do you have a vendor the bank is using and what issues has the bank come across.

Anything Else on Your Mind…

Questions? Thank you for your participation and input into the conversation! If you have any additional questions, contact Compliance Alliance at hotline@compliancealliance.com or 888-353-3933.