RESPA and Reg Z
Easiest places to earn Regulator criticism.
Dodd Frank hasn’t made this any easier.
Residential lending regulations (Reg Z and RESPA) have become ever more complex and confusing.
Most Reg Z and RESPA examination citations arise because the Dodd Frank requirements have not been fully assimilated into the bank’s procedures. Pressure to earn fee income (or save money) can cause a bank to overlook critical new compliance requirements. We help community banks update their Reg Z and RESPA procedures and follow through with measures to improve monitoring and training.
- Call to discuss your needs and to obtain our Certificate of Non-Disclosure and Privacy Agreement.
- If we’re only spit-balling, than skip Step 3. We don’t charge for conferences or to share our experience.
- Review our Fee Proposal. If it is acceptable, go to next step. NOTE: depending upon the circumstances, not all information request may be necessary. The rule of thumb: if you’re paying us, we want as much information as possible. If we’re just talking, then less information may be forthcoming.
- Provide some information for our discussion session. Some, all or none of the below maybe appropriate.
- Summarize examination comments (positive and negative) along with examiner recommendations and send those to us. Include in your summary both the written comments as well as any oral communication that took place. NOTE: we may not need to see copies of the actual comments; we can always review with a GoToMeeting session.
- Gather up your current policy and procedures along with any documents you use to open accounts or perform the work. You can scan and email to our secure portal or fax them to us.
- Gather your current reports you are using now to manage compliance.
- Summarize your current monitoring efforts; provide copies of reports used.
- We’ll send you a checklist you can use to help us understand the specifics of how you operate this part of the bank and how you are managing the compliance piece.
- We’ll send you the “prelim” policy and procedure in a MS WORD format to review and revise.
- We’ll schedule a follow-up phone conference to review your changes.
- We’ll send the revised Policy and Procedure.
- You provide credit card for our billing. (Payment by ACH and/or check is also acceptable.)
These guys are good. They helped get our program out of the ditch with a workable compliance plan – which they’ve updated for us twice. They managed to get a compliance team spirit going in the bank – even the BDOs are on board. The outside auditor has rated our program at a “9” (out of 10) for the past four years – and the auditor say, “I never give anybody a 10.”