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18 Cards in this Set
- Front
- Back
- 3rd side (hint)
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Went to send information package, conduct pre-exam interview, and send entry letter |
Info package-60-75 days
Pre-exam-60 days before on-site
Entry letter/CIDR 45 days before onsite |
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Risk to consider when reviewing a banks operating in developing a risk profile |
Performance risk Regulation risk Product/Serfice Risk |
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Areas that must always be TT regardless of mitigating risk factor |
Flood HmDa Fair lending |
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Situations when board meetings are required |
Significant problems that require consultations with the Regional Office
Informal or Formal Enforcement action is recommended
Rating 3,4,5
Upon banks request
CRA rating,state rating, or multi-state rating is needs improvement or substantial non compliance |
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Situation when board meetings are not required |
Visitations Consumer complaint investigation
Other on-site reviews |
These are area requiring a closing meeting |
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Board meetings are NOT required for |
Visitations
consumer complaint investigation
Other on-site reviews |
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Board meetings are NOT required for |
Visitations
consumer complaint investigation
Other on-site reviews |
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Contents of ROE in order |
Transmittal letter Cover page Examiner conclusions and comments -scope of exam Consumer compliance rating Compliance management Program Audit Recommendations Enforcement action CRA evaluation Meeting with management and board Violations page Supervisory comments |
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Element descriptors for each CMS component in the ROE |
Strong Adequate Weak |
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Element descriptors for each CMS component in the ROE |
Strong Adequate Weak |
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What to include in reimbursable TIL violation write up |
Support for the presence of a pattern or practice
Type of loan
Special characteristics or features
Number of loans samples with reimbursable violations |
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What documents should be uploaded to SOURCE |
Transmittal letter Cover page ROE,including Violations Page Supervisory Comments (page A) RPSM Enforcement Action Memos CRA PE Fair Lensing Memo |
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When to do visitations |
Newly charactered Recent or proposed merger Recent conversion to state nonmember status Review progress on corrective action since LX Ascertain compliance with enforcement action Investigative problems brought to FDIC's attention |
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Elements of 1 compliance Rating |
Institution in this category is in a strong compliance position -effective compliance program including efficient system of internal controls and procedures -changes in consumer regs are promptly reflected in FI policies procedures and training -adequate training to employees -if any violations are noted they relate to minor deficiencies and are easily corrected -no cause for supervisory concern -violations are promptly corrected by management |
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Components of the 2 rating |
An institution in this category is in a generally strong compliance position -although system of internal controls has been established violations have occurred -violations include technical aspect of the law or result from oversight on the part of operating personnel |
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Components of the 2 rating |
An institution in this category is in a generally strong compliance position -although system of internal controls has been established violations have occurred -violations include technical aspect of the law or result from oversight on the part of operating personnel -training is satisfactory -no evidence of discriminatory acts it practices resulting in repeat violations |
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Elements of a 4 rating |
Institution requires close supervisory action and monitoring to promptly correct the serious compliance problems disclosed
Numerous violations are present discriminatory actions may be in evidence internal controls are seriously deficient
Over charges affect a significant number of consumers and involves the Substantial amount of money
Discriminatory acts may be evidence
Managements attitude may indicate a lack of interest in administering an effective compliance program
Internal controls are seriously deficient |
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Elements of a 5 compliance training |
Institution is in need of strong supervisory action in monitoring -substantially in noncompliance of consumer regs - management has demonstrated its unwillingness or inability to operate within the scope of consumer regs -previous efforts by regulator to obtain voluntary compliance has been unproductive --discrimination substantial overcharges or practice resulting in serious repeat violations are present. |
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