Client Login
  • Home
  • About Us
    • History
    • Meet Us
    • Contact Us
  • Services
  • Reviews
  • Products
    • Seminars
    • Compliance Manuals
    • Other Products
  • Seminars
  • Compliance Resources
    • Newsletters
      • Newsletter Archives
        • 2007 Newsletters
        • 2006 Newsletters
        • 2005 Newsletters
        • 2004 Newsletters
        • 2003 Newsletters
      • Register
    • Compliance Links
    • Free Downloads
  • Contact Us
  • Blog
    • Proof of Flood Insurance - Part 1
    • Proof of Flood Insurance - Part 2
    • Late EFT Errors
    • FACT Act Red Flags and Address Discrepancies
    • Changing Late Payment Fees
    • CIP and Loan Officers
    • Consumer Complaints
    • SAR Filings Skyrocket
    • HELOC Renewals & Extensions
    • Consumer Help or Banker Headache?
    • "Government Made Easy" Yeah Right! (aka HUD's New RESPA Proposal)
    • An Update from a FDIC Field Examiner
    • Flood Answers...or More Questions? It's Your Time to Speak Up!
    • Flood Zone Discrepancies
    • SAR Tips
    • Regulator Hotline
    • FEMA Resolves Flood Zone Discrepancy Issues
    • The Best Compliance Manual
    • Office Fire
    • Flood Reform
    • Continuing To Share With Affiliates
    • Flood Insurance & Insurable Value
    • What I Learned at the ABA's RCC
    • ID Theft Prevention Program
    • Flood Insurance at Loan Closing?
    • UDAP (Unfair and Deceptive Acts or Practices)
    • ABA RCC Flood Issues
    • BSA Risk Rating
    • HMDA: What is Your HMDA Data Telling You?
    • Compliance Officers - Risk Rating & Prioritizing
    • New & Emerging Compliance Issues
    • Free OFAC List Searches
    • HMDA Getting It Right Updated
    • Paying A Bonus On Deposit Accounts
    • HMDA Plus
    • Right of Rescission
    • Flooding and a Bank's Reputation
    • Extension of the NFIP
    • New FDIC Insurance Increase and Signage
    • OTS Adverse Action Notices
    • FACT Act Exam Procedures
    • OFAC Searches
    • FTC Delays Red Flags Rule
    • FTC Red Flags Delay Update
    • Advertising Closed-End Loans
    • Application vs. Inquiry
    • HUD (or is it DUH!) Final Changes
    • RESPA Final Rule Issued
    • Common Violations and Risk Areas
    • Common Violations and Risk Areas - Continued
    • Consumer Compliance Handbook (November 2008 Update)
    • Getting Credit When Credit Is Due
    • A Little Friday Humor
    • Servicemember Civil Relief Act (SCRA)
    • CTR Exemption Changes
    • HOEPA Update Reminder
    • Effective Dates

Blog

FACT Act Exam Procedures

David Dickinson

By David Dickinson

They're out.  The much awaited exam procedures for the FACT Act sections that become effective November 1, 2008 (Red Flags, Address Discrepancy and Change of Address) have been released by the examining agencies.  The FRB press release indicates the Red Flag section will be reviewed by Safety and Soundness examiners while the Address Discrepancy and Change of Address requirements will be examined under the Consumer Compliance Examination process.

You can view/download each section by clicking on the following links:

Address Discrepancy Exam Procedures

ID Theft Red Flag Exam Procedures

Card Issuer Change of Address Exam Procedures

Typically, examiners do not implement changes in their examination process immediately.  They need time to learn the requirements and how they are going to examine institutions.  I predict examinations in the remainder of 2008 will not include these rules to their fullest extent.  If your institution has an exam scheduled in 2009, it's a different story.  Let us know how the examiners are interpreting these rules and how your exams go.  We have a great advantage point with over 500 client institutions and can pass on information to other banks awaiting exams.

If you need assistance implementing these requirements, contact us and we'll help.  Good luck!

 

 

This entry was posted on October 14th, 2008 at 12:00 am. RSS | Back to Blog Homepage.


View this document online at: http://www.bankerscompliance.com/blog/fact-act-exam-procedures.htm
© 2009 Bankers Compliance Consulting
All Rights Reserved.