General Loan Compliance Review

Generally, samples of each type of open-end and closed-end consumer credit offered by your institution will be reviewed for compliance with applicable regulations; this will include originated and non-originated applications. If the bank purchases dealer paper or originates consumer loans to applicants who are regularly referred to the bank by dealers, a sample of these loans will be reviewed for compliance with the FTC’s Rule regarding the Preservation of Consumer Claims and Defenses. A small sample of business loans will also be reviewed for their compliance with the Flood Insurance, HMDA, and ECOA regulations.

Training sessions will be provided during each visit to loan officers and support staff responsible for the completion of all loan-related documents. Training will be held at the conclusion of the review and will focus foremost on deficiencies uncovered during the review. Training sessions will include information regarding new lending-related regulations and/or upcoming regulatory changes. Handouts or Power Point presentations will be utilized to provide summary comments relative to the areas covered during training.

A review will be conducted which includes the following regulations as applicable:

  • Truth in Lending - Reg Z
  • Consumer Leasing – Reg M
  • Fair Credit Reporting (sections 609(g), 615(a), & 615(b))
  • Real Estate Settlement Procedures – Reg X
  • Flood Insurance
  • Homeowners Protection Act
  • Fair Debt Collection Practices
  • Preservation of Consumer Claims and Defenses
  • Equal Credit Opportunity – Reg B
  • Fair Housing
  • Home Mortgage Disclosure – Reg C
  • Credit Practices Rule
  • Consumer Protection in Sales of Insurance
  • Unfair & Deceptive Practices
  • Servicemembers Civil Relief Act
  • Safe Act




 


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