Loan & Deposit Review
A critical component to any compliance management system is a compliance review function. This building block enables the Board and senior management to monitor the effectiveness of the compliance program.
Loan Compliance Review
The Norman Group’s Loan Compliance Review will assess the client’s compliance management program by evaluating the lending-related risk assessment, policies and procedures, training, Board and management oversight, and status of prior exceptions, including the following, as applicable:
- FCRA
- CRA (Regulation BB)
- Truth in Lending (Regulation Z)
- Real Estate Settlement Procedures Act (RESPA)
- Regulation B (ECOA and Adverse Action Notices)
- Flood
- HMDA sampling (if applicable)
- Complaints
- Retail Sales of Insurance
- Home Ownership Counseling Act
- Servicemembers Civil Relief Act (SCRA)
- Military Lending Act (MLA)
- S.A.F.E. Act
- Appraisal Standards
- Loan Servicing
- ATR and QM
- Loss Mitigation
- Retail Sales of Insurance
- Homeowner’s Equity Protection Act (HOPA)
- Full file reviews of originated loans for closed-end real estate, open-end real estate, open-end other than real estate, closed-end consumer installment, and commercial loans for the review period for adherence to regulatory requirements.
- Full file reviews of adverse action applications for all types of consumer and commercial loans for the review period for adherence to regulatory requirements.
- Periodic billing statements used for various consumer loan types.
- Annual escrow analysis statement requirements.
- Required FCRA notices.
- Advertisements and marketing outreach activities during the scope period.
Deposit Compliance Review
The Norman Group’s Deposit Compliance Review will assess the client’s compliance management program by evaluating the deposit-related risk assessment, policies and procedures, training, Board and management oversight, and status of prior exceptions, including the following, as applicable:
- Truth in Savings (Regulation DD)
- NOW accounts (Regulation D)
- Electronic Funds Transfers
- Funds Availability (Regulation CC)
- FCRA
- Unlawful Internet Gambling (Regulation GG)
- Can-Spam Rule
- Telephone Consumer Protection Act
- Physical Security
- Privacy Notices and Right to Financial Privacy
- Website
- UDAAP Program, Risk Assessment, and Consumer Complaints
- Advertising
- Regulation E disputes
- Periodic statements
- ATM deposit and withdrawal receipts.
- Overdraft opt in/out program requirements.
- Outgoing foreign wires and ACH transactions.
- Regulation CC holds and disclosures.
- Early withdrawal penalty requirements.
- NOW account eligibility
- Denied deposit accounts and ATM/Debit card applications.
- Change in terms notices.
- Account disclosures (TISA, EFT, Check 21, Funds Availability, etc.)