By Cody Roberts, CRCM
Occasionally, a governmental agency issues a helpful document. Recent straw polls of compliance officers suggest this would not include the new Uniform Residential Loan Application–which now stretches to 7 pages minimum for a purchase loan (see our recent blog entry here on this form). Nor would this include the Department of Defense’s recent MLA regulatory changes. While the DOD oversees the world’s bravest men and women serving in the armed forces, it’s apparent that writing consumer lending regulations is a little out of the DOD’s wheelhouse.
However, one document that does help compliance personnel is the OCC’s Semiannual Risk Perspective. Written by the National Risk Committee, it contains an overview of what the OCC—and typically the other prudential regulators as well—consider “key issues facing banks, focusing on those that pose threats to the safety and soundness of banks and their compliance with applicable laws and regulations.”
For example, the spring 2016 version is (thankfully) only 34 pages and notes that “compliance risk remains high” and that key compliance risk issues include the following:
– Increased BSA/AML Risk Observed in New Offerings and Strategies
– Military Lending Act
– Truth in Lending and Real Estate Settlement Procedures Act Integrated Disclosure/Know
Before You Owe Rule
Trends are explained sufficiently and frequently graphically as well. In addition, each of the individual issues is discussed in enough detail to help guide you to what is important without making your eyes glaze over.
I recommend reviewing this document on a regular basis. As a result, you can make sure you know what the regulators think is important for your next exam.
Did you know that ABS offers a library of compliance monitoring and risk-management procedures and file reviews that addresses BSA/AML, the Military Lending Act as well as TILA and RESPA? Check out CompliancePro on our website here or call us at 800-522-4990 for more information.