OCC is directing national banks to conduct self-assessments of foreclosure management practices by September 30th. Does anyone already have a template they would be willing to share? I have a complete compliance assessment that I complete every year, however this one needs to be just foreclosure procedures. Any help would be greatly appreciated.
My best days are yet to come.
and they say this: ... Boards of directors should ensure that management has addressed these areas.
To me this means we should have a policy statement (board approved). I simply paraphrased the guidance from the bulletin and then wrote a checklist that itemizes the stuff we say we will do in the policy.
EIC stated that my report is the best he has seen in the ones they review, but still is not satisfactory. We are getting an MRA on this. Scope inadequate. Report not detailed enough - no numbers, nothing about MIS reports, nothing on third party attorneys qualifications testing monitoring board approval, (OCC 2001-47). So back I go to redo.
Zitch 70 - Issued an MRA for this one??? Wow. We are a small bank (less than $60M)and had an OCC exam in December. We had not completed a self-assessment, but fortunately we also had not had many foreclosures over the last year or two. I completed a self-assessment using the format provided in the guidance (OCC 2011-29) and it's only one page. They were satisfied. I have also added a small section to our loan policy regarding this and OCC 2011-49, which is related to residential foreclosures. Hope this helps.