Large Bank Compliance Huddle june 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?

Compliance for Commercial Lenders More specifically?

Flood Who is responsible for verifying that appropriate flood insurance is obtained at closing? The Lender or loan administrator or both? Who is responsible for training a new lender or loan administrator? Compliance or someone in the commercial department? Who is responsible for the same in loan operations? How involved does the compliance area get with this process?

ECOA Does your Commercial Lending Department utilize a formal written Loan Application form? How are correct, completed application dates and notification of action taken monitored in commercial? Is the lender and/or loan administrator responsible for documenting the appropriate dates if a commercial loan application is not used? How is this documented? Who is responsible for ensuring that the appropriate appraisal notices are sent? Who is responsible for ensuring that a spousal guaranty is not improperly required? Who trains new lenders and loan administrators on this?

Reg CC Amendment

HMDA Who trains a new lender or loan administrator on the HMDA requirements and the process for collecting this information? There are a significant number of changes applying to commercial as it relates to the new rules effective January 2018. How do you administer this training? Does the compliance area do it or is the information passed to Commercial Lending Management to distribute?

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.