Volume 9, Number 2 This issue went to press on March 15, 2004.
Table of Contents
OCC Speaks Out on Consumer Complaints (7 Action Steps)
There has been a lot of controversy and heated debate over the recent OCC preemption rule. In spite of all the fuss, the OCC's position is not new or different. Advisory Letter 2004-2 is yet another step the OCC is taking in this arena.
CRA: Solving the Investment Test Problem (6 Action Steps)
For most institutions, the investment test is the most difficult and confusing part of the CRA examination. This guidance gives both clarification and a measurement tool.
Action Audit
Checking Applicants and Signatures (8 Check boxes)
Under revised Regulation B, examiners will be looking for evidence that the application is intended to be joint - or multiple - in the loan file itself. Your audit should look for it first.
Compliance Notes
In the Editor's Opinion: Warren Dennis: A Fair Lending Legend
Leaving behind an impressive legacy, Warren Dennis made a remarkable difference in the world of fair lending.
Compliance Q&A
The Preemption Debate Gets Hotter
The rule itself is under attack but the real debate is less about consumer protection and more about power.
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