Learning from the mistakes of others is one of the best ways to stay out of hot water with examiners.
Our review team has the privilege of going into several financial institutions a week to observe where their struggles lie.
It’s not uncommon for different banks to struggle in the exact same areas. We had our review team compile the top violations they’ve seen this year in the areas of Lending, Deposits, and BSA/AML.
Jerod explains more in the video.
I mention in RESPA Mortgage Servicing, Real Estate Settlement Procedures Act, that servicing issues, in general were a hotspot. Here it comes up again on page number 10, letter D, and we're going to expand a little bit. So just general loan servicing, auto, personal, commercial, and agricultural loans. And then the collections practices. The Fair Debt Collection Practices Act just got updated. Many of you probably are listing, and you're not subject to the Fair Debt Collection Practices Act. That's fine, but then your collection practices fall under the wing of the Unfair, Deceptive, or Abusive Acts or Practices Act, which is way more subjective anyway, and eye-of-the-beholder-type stuff. So make certain that you're not going too far regarding collections and just general servicing of loans. Learning from the mistakes of others is the best thing to do there.
Published
2022/12/01