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Compliance Huddle. March, 2017. Recent Exams. Does anyone currently have examiners on-site? Is there still a continuing increase in request information? What is the focus of the on-site? Has anyone just been through an exam or recently received their ROE?
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Compliance Huddle March, 2017
Recent Exams • Does anyone currently have examiners on-site? • Is there still a continuing increase in request information? • What is the focus of the on-site? • Has anyone just been through an exam or recently received their ROE? • Has examiner “tone” changed from the last on-site? • Are the reports giving credit where credit is due, or if there were concerns, are the reports written in such a way that the regulators are seemingly sympathetic or more demanding? • What are some of the areas of focus?
Disaster Planning • Business continuity plans, when was the last time you reviewed it? • Natural disasters: • Flood • Earthquake • Tornado • Hurricane • Other disasters: • Extended power outages • Network outages • Cyberattack • These are problems, but also an opportunity to show how vital you are to your community in times of need.
Prepaid Cards • Do you offer them? • What issues are you dealing with? • What about payroll cards? • CIP?
Beneficial Ownership Rule • Lots of confusion – how are you handling it? • Training for bankers • Certification form • Who are you getting CIP information on?
Mortgage Loans • Loan Servicing Transfers • Some unique situations: • Successor-in-interest transactions and dealing with the estate • Assumptions • Owelty liens (divorce) • Any others?
Questions? Thank you for your participation and input into the conversation! If you have any additional questions, contact Compliance Alliance at hotline@compliancealliance.com or 888-353-3933.