Common Violations

While there’s typically a wealth of compliance information available to you at any given time, we still believe that some of the most useful and beneficial information is BSA Training and Banking Regulations Compliance Consulting diane11 - Common Violationswhat examiners are citing during exams.  Not only can it alert you to different or new areas of focus, it also gives you some direction when planning training or during the course of your own internal reviews (or both)!  We also believe it’s good to look at what Regulators, other than your own, are citing.  Knowledge is power!!

Here are some common violations recently noted by the Federal Reserve:

HMDA

  • Incorrect data reporting

Regulation B

  • Not documenting and retaining evidence of joint intent
  • Not completing monitoring information if applicant fails to do so

Regulation Z

  • Content of disclosures, specifically finance charges

FCRA

  • Not indicating the use of a credit report on an adverse action notice

Flood

  • Inadequate coverage at some point over the life of the loan or as a result of cross-collateralization

Overall program weaknesses, resulting in Matters Requiring Immediate Attention (MRIA) or Matters Requiring Attention (MRA) in areas such as Fair Lending, Training, Secondary Reviews, Risk Assessments, RESPA/TILA, CRA, Flood, and others, have also been cited.

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Published
2017/07/06
Diane Dean

 

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