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 what 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:
- Incorrect data reporting
- Not documenting and retaining evidence of joint intent
- Not completing monitoring information if applicant fails to do so
- Content of disclosures, specifically finance charges
- Not indicating the use of a credit report on an adverse action notice
- 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.