Accuracy and Integrity Policy/Procedure Requirements
05/28/2017
Does my financial institution have to have policies and procedures regarding accuracy and integrity of furnished information provided to CRA’s?
Kelly M. Owsley, CRCM is Director of Training Services for Compliance Resource, LLC. Kelly's career in banking began in 2000. Since then she has worked for financial institutions ranging in asset size from $250 million to $3 billion. Kelly has worked in numerous areas of the financial services industry including retail branch management, lending, product development and training. In addition, Kelly spent three years in a training and development role with CUNA Mutual Group servicing the largest credit union in the United States. Most recently, she served as the Vice President of Compliance, BSA Officer, and CRA Officer for a community bank in Kentucky where she was responsible for implementing and training all compliance related topics. Kelly holds a Bachelor of Science degree in Accounting from the University of Kentucky and is a Certified Regulatory Compliance Manager.
05/28/2017
Does my financial institution have to have policies and procedures regarding accuracy and integrity of furnished information provided to CRA’s?
05/21/2017
We were cited in our last exam for not having a permissible purpose to pull a credit report; however, I can’t find information in the regulation regarding permissible purpose. Where can I find this information?
05/14/2017
I am a new lender and have never pulled a credit report that included a fraud alert. Are there certain steps I must take before I can move forward with the loan?
05/07/2017
Our financial institution has noticed an increase in cases of identity theft among our customer base. What can we do to prevent this from occurring?
04/30/2017
We have been providing the Notice of Negative Information at loan closing; however, I was told by an auditor that it is required to be provided on the notice we send when the borrower has defaulted. Is this accurate?
04/30/2017
We have never disclosed the MAPR. Are there changes that require us to do so now?
04/23/2017
Our software calculates the finance charge, the APR, the rate spread and the total of points and fees for us. Isn't our risk of a fee disclosure violation therefore very limited?
04/16/2017
We don't make high-cost mortgage loans covered by section 1026.32, so we don't need to worry about the "total of points and fees." Right?
04/09/2017
We live by the axiom “When in doubt, include the fee in the finance charge.” Doesn't that protect us from violations?
04/02/2017
What is the easy way to avoid fee-related disclosure problems?