As most of the requirements going into effect in January 2014 apply to new applications it might be very easy for banks to overlook those requirements that affect their existing loans. If you haven’t done so already, you will want to determine whether the following requirements apply to you very soon.
If you originate adjustable rate mortgages subject to Regulation Z or are considered a large servicer subject to the periodic statement requirements, you need to make sure your systems and vendors are ready to roll with the requirements as they apply to your entire loan portfolio. You will want to review not only the content of any required statements and/or notices, but also test the system to ensure the statements and/or notices are being generated in a timely manner in line with the new requirements. Also, if you are going to use coupon books to meet the periodic statement requirements, do you need to order new ones?
These requirements take effect January 10, 2014, and if you act now you will hopefully have time to address any issues by January!
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!