FED Top Violations - Part 2
By David Dickinson
Recently, our local compliance peer group met with a Kansas City FRB Examiner. She informed us of the Kansas City Regions' top violations. This information was gathered from 55 bank reviews from January 2008 until May 2009. I previously wrote about violations #1-5. This blog is about #6-10.
#6 - Flood: Not completing a Standard Flood Hazard Determination Form
#7. - Flood: Inadequate insurance. - the "biggy". This can result in Civil Money Penalties being accessed! Either no insurance (coming late), wrong amount or lapses in coverage.
#8. - RESPA: accuracy of charges & not listing the ultimate recipient.
#9. - RESPA: Not providing the Good Faith Estimate within 3 days. Warning: the new definition of "application" will make this even more difficult.
#10. - RESPA: Required Provider (various issues). Going away with new RESPA rules.