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August 5, 2015
HMDA – Beyond the Input
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#1585311 - 07/29/11 01:11 PM Foreclosure Management
3-2-go Online
Gold Star

Registered: 11/12/08
Posts: 388
Loc: East
Anyone started on the self assessment for this?

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General Discussion
#1588708 - 08/06/11 09:28 AM Re: Foreclosure Management [Re: 3-2-go]
3-2-go Online
Gold Star

Registered: 11/12/08
Posts: 388
Loc: East
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.

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#1588710 - 08/06/11 02:41 PM Re: Foreclosure Management [Re: 3-2-go]
Kathleen B Online


10K Club

Registered: 12/27/00
Posts: 19193
They actually want more than a risk assessment. They want a self-assessment:

"The self-assessments should include testing and file reviews and be appropriate in scope, considering the level and nature of the bank’s mortgage servicing and foreclosure activity."

The self-assessments should include testing and file reviews and be appropriate in scope, considering the level and nature of the bank’s mortgage servicing and foreclosure activity.

For the risks, start out with list each of the points in the guidance and add in your practices, policies and controls on each item. Assess your risk from there.
_________________________
Kathleen Blanchard CRCM "Kaybee"
Lending/CRA/HMDA/Mapping/Consulting
www.kaybeescomplianceinsights.com

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#1589238 - 08/08/11 04:49 PM Re: Foreclosure Management [Re: Kathleen B]
Cornhusker Offline
Gold Star

Registered: 03/25/11
Posts: 366
Loc: SE, Nebraska
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.

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#1658677 - 01/31/12 04:18 PM Re: Foreclosure Management [Re: 3-2-go]
Funky Falcon Offline
100 Club

Registered: 01/10/08
Posts: 217
Loc: Minnesota
Has anyone heard about the OCC extending the completion deadline from Sept. 2011 to June 2012??? I heard that from someone today, but can't find proof of it.

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#1658788 - 01/31/12 07:40 PM Re: Foreclosure Management [Re: 3-2-go]
Princess of Power Offline
Gold Star

Registered: 08/23/02
Posts: 403
Loc: Napa, CA
My EIC (OCC) has asked for it already. So she has the policy & self risk assessment for review right now & am awaiting her comments.

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#1679597 - 03/20/12 09:29 AM Re: Foreclosure Management [Re: Princess of Power]
zitch70 Offline
Gold Star

Registered: 04/05/01
Posts: 331
Loc: Edinburg, Texas
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.

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#1681612 - 03/23/12 12:35 PM Re: Foreclosure Management [Re: 3-2-go]
Karen45 Offline
New Poster

Registered: 01/31/08
Posts: 1
can anyone provide me with a template for the foreclosure self assessment?

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#1682085 - 03/26/12 11:06 AM Re: Foreclosure Management [Re: 3-2-go]
POWFNB Offline
Junior Member

Registered: 10/26/09
Posts: 32
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.

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#1683997 - 03/29/12 05:59 PM Re: Foreclosure Management [Re: POWFNB]
Marnie Online
Gold Star

Registered: 11/13/07
Posts: 435
Anyone know if FDIC has addressed this as well? Anyone regulated by FDIC voluntarily doing this?

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#1787248 - 02/19/13 12:00 PM Re: Foreclosure Management [Re: Marnie]
lvc Offline
Platinum Poster

Registered: 07/11/07
Posts: 941
Bump

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#1797172 - 03/21/13 12:32 PM Re: Foreclosure Management [Re: 3-2-go]
DeeQ Offline
10K Club

Registered: 12/04/02
Posts: 40598
We are being hounded that our FC Assessment is not detailed enough. Really? We have a very low FC rate and our procedures are simple. mad
_________________________
Sì, si, io sono il diavolo della regina
CRCM/CCEP

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#1797230 - 03/21/13 01:32 PM Re: Foreclosure Management [Re: 3-2-go]
E.G.B. Offline
Power Poster

Registered: 07/23/02
Posts: 6578
Loc: the sandy shore
"Simple" is probably the issue for them. They apparently want detailed.
_________________________
I must go down to the seas again, to the lonely sea and the sky.

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#1797246 - 03/21/13 01:43 PM Re: Foreclosure Management [Re: 3-2-go]
Kathleen B Online


10K Club

Registered: 12/27/00
Posts: 19193
I worked with a bank (former OTS) to beef it up. They had to add detail...how many, #, $, trends.

I reviewed it and made additions to how they described their processes to emphasize the OCC focuses on. You want detail, numbers.

Don't cross reference procedures...say it. It should be a standalone document that gives a complete picture.
_________________________
Kathleen Blanchard CRCM "Kaybee"
Lending/CRA/HMDA/Mapping/Consulting
www.kaybeescomplianceinsights.com

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