Large Bank Compliance Huddle March 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?

Mortgage Servicing How are you managing your relationship with service providers? Policies Procedures Complaints Copies of agreements

Mortgage Servicing Amendments Definition of Delinquency: 10/19/17 Requests for Information: 10/19/17 Force-Placed Insurance: 10/19/17 Early Intervention: 10/19/17 Loss Mitigation: 10/19/17 Prompt Payment Crediting: 10/19/17 Other Periodic Statement Requirements: 10/19/17 Small Servicer: 10/19/17 Bankruptcy Periodic Statement: 4/19/18 Successor-in-Interest: 4/19/18

HMDA First Phase: 1/1/17 Primarily affects low volume institutions, not much change for larger institutions Second Phase: 1/1/18 Effective date for most provisions New data collection fields required Third Phase: 1/1/19 Elimination of Appendix A and Revised Procedures Last Phase: 1/1/20 Quarterly reporting

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? Any indication if providers will be ready? Budget: how much is this going to cost? Any other concerns?

Enforcement Actions and News Nationstar – HMDA Violations PHH Amicus Brief

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.