We will perform a review of the regulations associated with lending compliance, including the following:

• Truth in Lending Act/Regulation Z (Open- and Closed-End Credit)
• Real Estate Settlement Procedures Act/Regulation X (RESPA)
• Flood Disaster Protection Act
• Equal Credit Opportunity Act/Regulation B
• Fair Credit Reporting Act (FCRA)
• FRB Fair Housing Regulation
• Unfair and Deceptive Practices Act/Regulation AA
• Sales of Insurance Products (e.g., credit life)
• Servicemembers Civil Relief Act (SCRA)
• Homeownership Counseling

We will perform a review of the regulations associated with deposit/operations compliance, including the following:

• Truth in Savings Act/Regulation DD

• Expedited Funds Availability Act/Regulation CC

• Electronic Funds Transfer Act/Regulation E

• Interest on Deposit Regulations (Savings/MMDA Monitoring Procedures)

• Consumer Privacy/Regulation P  

• Right to Financial Privacy Act (RFPA)

• Advertisements/Office Signage

• Unlawful Internet Gambling Act/Regulation GG

• Overdraft Program

We will perform an independent test of the bank's compliance with the Bank Secrecy Act (BSA) and Financial Recordkeeping Regulations.  This analysis will satisfy the independent testing requirements outlined in the FFIEC Examination Manual.  During our review, we will assess compliance with the following areas:

• Bank Policies and Procedures

• BSA/AML/OFAC Risk Assessment

• Customer Identification Program (CIP)  

• Customer Due Diligence (CDD)

• Currency Transaction Reporting

• Exemptions from CTR Requirements

• Accuracy of Reports Used in Detecting Reportable Transactions

• Suspicious Activity Monitoring and Reporting

• Recordkeeping for Monetary Instruments and Funds Transfers 

• Money Service Businesses (MSBs) 

• Currency Shipments 

• Electronic Banking Activities

• ACH Originators

• Office of Foreign Asset Control (OFAC)

We will review Fair Lending Related Regulations using a "side-by-side" comparative file analysis, which will be based upon an evaluation of the bank's fair lending policies, procedures and practices. 

An "underwriting" or "pricing" analysis will be performed on samples of "target" and "control" group applications and loan originations.  

We will assess the bank’s compliance with the SAFE Act by reviewing the bank’s policies and procedures relating to the SAFE Act.  We will also evaluate the registration and renewal procedures of the bank, the methods of providing the customer the unique identifier, and the bank’s training program for registered lenders. 

We will review compliance with the HMDA by providing an independent assessment of your processes and an audit of the Loan Application Register (LAR) accuracy to ensure compliance with the Regulation. 

The analysis will include a sample of LAR items to review the accuracy of the data collection and ensure that the information was entered into the LAR correctly.  In addition, we will review the bank's procedures and offer any recommendations to enhance compliance with the HMDA. 

We will review the bank's compliance with the lending and service tests as outlined in the Community Reinvestment Act by analyzing the following areas: 

• Reviewing current CRA-related program and providing recommendations for enhancing the program;
• Reviewing the bank’s current loan programs in relation to CRA;
• Assisting in the analysis of CRA compliance and the development of documentation (i.e., graphs, maps, ratio and other analyses) to support CRA compliance efforts;
• Evaluating the bank’s current demographics and assessment area;
• Analyzing each census tract in the Bank’s assessment area to evaluate the volume of lending in each tract; and,
• Evaluating the Bank’s out of territory lending issues.

We offer reviews to assess the bank’s compliance with the FCRA red flags rules.  This will include a review of both the lending and deposit areas.  We will also evaluate policies and procedures to ensure compliance with the regulatory requirements.

We offer training sessions tailored to job specific duties (from bank personnel to the Board of Directors) in all areas of compliance, including BSA, Fair Lending, and HMDA.  

We also offer a web based training program.  Look here for a lsiting of topics as they become available.