FACT Act Exam Procedures
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
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!