|314(a) Documentation Spreadsheet|
BOL user Peg Eekhoff has created a spreadsheet to be used in connection with processing Section 314(a) search requests from FinCEN. It outlines each of the seven areas a financial institution must search, and makes it easy to document that the search was performed.
314(a) Compliance Checklist
It's not enough to simply perform the searches required by the USA PATRIOT Act Section 314(a) information requests and report matches. It's also important to document the steps you took. Liz Slim came up with a checklist for documenting the searches for FinCEN 314(a)information requests. Save yourself some time by starting with her form! 314(a) "What to Search" Cheat Sheet
Make sure you're searching through everything you need to be searching through. Use Mary Beth Guard's cheat sheet for what to search under 314(a).Adverse Reasons Chart
Need help determining how to describe the reasons for adverse action you're taking? This handy chart developed by Jim Bedsole and the crowd at The South Financial Group outlines various reasons and provides a guide to when it’s appropriate to use them. You'll simply need to customize it to fit your own institution's credit policy before use.Advertising Checklist
BOL Guru Jim Bedsole has furnished an advertising checklist that was developed and used by The South Financial Group. It has separate sections for NDIP, general advertisements, and various types of lending ads (closed end, open end, HELOC). Wow!A Guide to Bank Compliance Research
Mary Beth Guard has authored this comprehensive resource to help you understand how to perform research into laws, regs, court cases and more.
ARM Disclosures - Disclosure Spreads
BOL Advisory Roundtable member Al Miller has provided four spreadsheets he uses for disclosure spreads on ARM loans.Audit Action Items Tracking Report
This tracking report form (right click to save the file) provided by Bob Simpson of Machias Savings Bank, will be useful to follow up on those outstanding audit issues. You complete the audit, weaknesses are found and tasks are assigned for corrective action. How are these followed-up on or are they just forgotten until the next audit? Action needs to be taken and this tool will keep the tasks and accountability on the radar screen until this is done. You may also view this tracking report form as a PDF.
Lori Moore of Citizens Bank Texas, also has a tracking report. She uses Excel and has noted that this is useful for tracking internal/external audits and those comments from regulators where corrective action is also very important. Lori moves the audit issues from the "Outstanding" tab to the "Completed" tab to draw a clear distinction on what is yet to do, and what has been accomplished. Download this Excel document by right clicking this Audit/Exam Tracking Report. You may also view it in PDF form.
Boo Boo Forms
Boo Boo Forms - a humorous and gentle tool for communicating about compliance violations on loan documentation. Could easily be adapted to other areas of compliance.
BSA Exam Questionnaire - FDIC
This spreadsheet ICQ is a "usable" version of the FDIC questionnaire from FIL 0379B. If you like using your own customized or electronic form audit workpapers, Patrick Ryan of Citizens Commerce National Bank has ported the FDIC BSA Exam Questionnaire to Excel. This can be a real time-saver when you like your audit workpapers on your hard drive.
BSA Exemption Analysis
This spreadsheet tool furnished by BOL Guru Richard Insley, helps you perform a cost/benefit analysis on Phase II exemptions under the Bank Secrecy Act.
BSA Exemption Review
Background on the BSA Exemption Review Form
.doc version (right click on link and save the file to your hard drive)
Cheat Sheet for Adverse Action Notice Completion
There's the ECOA adverse action notice. Then there's the FCRA adverse action notice. Different guidelines apply to when they're given and to whom they're given. Buffy Dyess has constructed a Cheat Sheet to help you understand what to complete and who to give it to!
See the Lender Tools section for Checklists for Real Estate loans!
Community Development Tracking Forms
Dawn Lowrie developed these templates to use as worksheets on community development investments, loans, donations and services. Each form answers the specific questions the OCC posed during her bank's last exam and were developed with input from their request. She scans in copies of documents pertinent to the investment/donation and provides the examiners with both a hard copy of these docs and a CD ROM version of the bank's file.
CRA Codes for Small Business Loans
A BOL User prepared a condensed version of the CRA codes for small business records from the FFIEC File Specs. With the file specs column removed, it's more user-friendly.
CRA Community Development Loan Report
Susan deFreese provided this CRA Community Development Loan Report form that she developed and uses system-wide. She says it is a challenge to get loan officers and loan administrators to identify community development loans. The form certainly goes a long way toward solving that problem!
CRA Tools: Some Help for the "Lending Test"
CRA data is out there, but it's nice to have it organized for you. Len Suzio, with GeoDataVision, has provided BOL with two documents that could make your reporting easier. The first, listing lending by region, will help when comparing how you stack up against the competition in your assessment area. The second document organizes community development lending in the same way. Since your CRA numbers are judged in a "performance context", these tools are sure to come in handy. Both are stored in the Acrobat .pdf format.
CRA Self Examination Checklist
BOL user David Kreiman contributed this CRA self-examination checklist that he developed for annual use. It sums up the majority of what he does for CRA. Try customizing it for use in your institution.
CRA - Large Bank Worksheet
In response to this thread, Bonnie Mizrahi has contributed a document she developed a couple of years ago for CRA loan data when she used to individually input loan information. CRA - LOAN INFORMATION SHEET - Addendum to Credit Memorandum CRA Worksheets
Background on the CRA Service and Lending Worksheets
CRA Service Worksheet in Word .doc format (right click on link and save the file to your hard drive)
CRA Lending Worksheet in Word .doc format (right click on link and save the file to your hard drive)
PLUS another version of a CRA Community Development Service Worksheet, this one furnished by Cheryl Wiza. Customize it with your own institution name and person to route it to.
CRA Data Collection Worksheet
Karen Kopcza has designed a CRA Data Collection Worksheet that appears to be very helpful and user-friendly. Access the data collection worksheet and instructions below. This was a pre-2004 HMDA form as well. They are in Word .doc format.
eBanking Audit Program
Also submitted by MackenzieS is an Internet Banking Audit Program. This audit program was obtained through auditnet.org's website, where all users have access to these programs. This is a very extensive audit program, and should be tailored to each institution's audit needs.
Fair Credit Reporting Act
We have provided a hyperlinked version of the Fair Credit Reporting Act in both Word and PDF forms so you can easily navigate them and add e-notes and bookmarks on your own. This is the FCRA inclusive of the FACT Act revisions, and all other amendments through July 2010 (it includes the Dodd-Frank Act amendments). Reg. V is being written based on parts of this law. This isn't a substitute for Reg. V, but its source.
Fair Lending Worksheet - Georgia
BOL User Lori Peterson contributed this worksheet which was developed to help mortgage lenders in Georgia discern what is a "finance charge" under Regulation Z and what are considered "points/fees" under the Georgia Fair Lending Act.
FDIC's Compliance and Document Request
Beginning June 30, 2003, this is a sample of what institutions who have FDIC as their primary federal regulator will be receiving. 20 pages of items they'll be asking for, from descriptions to trial balances to policies to forms.
Flood Insurance Cheat Sheet
This handy flow chart from BOL Guru Mary Beth Guard makes it easy to see at a glance when you must do a flood determination, when flood insurance is required and the steps you must take to be in compliance.
Flood Insurance Coverage Form
Susan deFreese created this form to determine if flood insurance coverage is adequate by adapting it from an OCC form that was given to a member of our local compliance association. With flood compliance being the subject of so many recent enforcement actions, this form should be a lifesaver.
FRB Consumer Compliance Handbook
The Federal Reserve Board released an updated version of their compliance exam workpapers, January 2006. This is an excellent resource for compliance management and auditing as well as having instructional content. BOL has taken the 27 separate files and combined them into one 348 page manual that is indexed and searchable for ease of use. (You must RIGHT click on link and save the file to your hard drive.)
Flood Insurance Wallpaper
Flood Insurance "Wallpaper" for Your Computer Desktop - increase awareness of the importance of flood insurance requirements by using these graphics as the wallpaper on your institution's PCs for a while. There are two sizes to the graphics. Choose the one that matches your screen resolution.
HMDA Getting It Right Primer
Here's a training handout designed by Jeanette Nichols CRCM, now a consultant for First Colebrook Bank in Colebrook NH. She served as Compliance Officer and HR Director for the bank prior to retirering to Nevada. She contributed a HMDA Getting It Right Primer document you'll want to distribute as a reference tool as well as a training resource. It covers the basics of what accounts should be on the HMDA LAR based on purpose and the loan itself, taking the user step by step through the general requirements of reportability. Then there are loan scenarios and explanations as to why they should or should not be reported.
HMDA Input Reporting Worksheet
Here's a handy worksheet, designed by Nancy Anderson of Stockman Bank, updated for 2004 by Dan Persfull of The Peoples State Bank, to help lenders capture data necessary for HMDA reporting. It's in Word .doc format.
Dave Majowski of Farmers-Merchants Bank & Trust Co. provided a HMDA Input Reporting Worksheet he uses. He validates all information compiled on this sheet by loan officers, calculate the rate spread if necessary, then keys it in the HMDA software. It's in Word .doc format.
Dan also provided a separate HMDA Data Collection form for those times when GMI is required, but a URLA 1003 isn't used.
HMDA MSA and Micropolitan SA Spreadsheet
This tool from Don Narup, frequent Threads poster and head of CRA Information Services is an Excel spreadsheet which will help get you up to speed on changes to MAs for HMDA purposes.
Hot Issues Cheat Sheet
This one page matrix by Mary Beth Guard provides a quick reminder of what is covered by GLB Section 501(b) and USA PATRIOT Act sections 314(a), 314(b), and 326, to help you keep it all straight.
Internal Audit Manual for Small Banks
This Internal Audit Manual for small banks was prepared by BOL User MackenzieS, and the sample Audit report was created by BOL User Wlovoie. This manual is a good tool for banks that are trying to create uniformity within their audit program.
Information Security Access Assessment
This is a checklist Bonnie Mizrahi and staff have been developing for use in their branches as part of our Customer Information Security program under GLBA. It is an excellent tool for covering the bases.
(SEE other Information Security tools in various parts of Banker Tools)
Lobby Notice Requirements Chart
Want to be certain you have all the required lobby notices posted in each place where they need to be? Barbara McGuire has developed a chart that makes it easy. It notes each of the lobby notice requirements, where they must appear, the underlying regulation, and any special instructions that should be observed.
Logos for Your Website
Tired of looking for images you need for your website? Here are several sizes of the Equal Housing Lender, Equal Housing Opportunity and FDIC logos you need to comply. Monitoring Information Collection Guide
Jim Bedsole has prepared a handy guide for determining when government monitoring information should be asked for by financial institutions subject to HMDA. He's made it available in both a Word doc and a PDF file.
HMDA Guide in Word doc (right click on link and save the file to your hard drive)
HMDA Guide in PDF
New Account Compliance Checklist
This checklist helps the new account representative, auditor or compliance officer verify that the regulatory requirements for new accounts were met OFAC- Potential Hit Analysis Spreadsheet Sample -- Because her bank has experienced a large number of false positives with the OFAC list, BOL Advisory Roundtable member Bonnie Mizrahi developed a spreadsheet for use in analyzing and documenting potential hits. In it, she details why a particular customer is not a true match for the name on the OFAC list. By using this as a sample, you can develop a similar tool for your own institution.OFAC Procedures
Pam Johnston works in a centralized operations environment for a bank holding company and has provided two different files for OFAC procedures: one is for the bankers, and one file is forher operations center. Pam compiled these procedures after reading all of the Reg, multiple ABA articles, the message threads on the BOL site, and participating in Mary Beth Guard's OFACtelephone seminar. These should serve as useful resources for others who are struggling with getting a procedure in place.
Predatory Lending Spreadsheet
Need information about predatory lending laws? BOL User Shelley Armentrout has prepared an Excel spreadsheet to help keep it all straight. It was developed to help keep her institution from originating predatory loans. Have additional data you could add? Let us know!
PMI Notice Language
PMI notice language - suggested language for the annual PMI notices for loans originated after 7/99 (from the Banker's Threads)
Privacy Police Tools
Privacy Police graphics - a humorous, but effective, way to let your employees know they've been caught with an information security infraction.
Regulation B - Required Signatures
This flow chart helps make clear whose signature you can require on what documents under the Equal Credit Opportunity Act. We prepared it based upon a chart developed by the Philadelphia Federal Reserve Bank.
Regulation B Compliance Worksheet
This worksheet used by the OCC to examine for technical and procedural compliance with Regulation B was provided by a BOL user
Reg CC Resources
Reg CC Resources for Compliance and Training
- Reg. CC Hold Notice example
- Reg. CC Reference Guide Patrick Ryan of Citizens Commerce National Bank has provided some useful tools. Here is his Reg. CC Hold Notice and a separate Reference Guide. These tools helped Patrick's tellers. They also print these in carbonless copy sets for retention and the address (which you can change since this is in Word) will fold and show in a window envelope for efficiency. You may find these useful when customizing your own forms and training. Thanks to Patrick and other contributors, you don't have to start from scratch.
- Reg CC Date Availability Calendar/Spreadsheet from Jim Bedsole & Andy Zavoina. Updated 01-02-04. Make sure you have the latest version! This Excel spreadsheet is designed to allow a user to calculate when funds must be made available under Reg CC. It is date-specific, and has been updated for use during 2004. Be sure you turn on the Analysis Tool Pak-VBA as noted in the steps on the Output tab. Also, the business day is set to go forward based on a 2 PM cutoff. But any date may be put in that cell.
Reg D Chart - Limitations on Withdrawals and Transfers from Savings Deposits
Reg D is all about correct calculation of reserves. To calculate reserves properly, you must classify accounts the correct way. For savings deposits, that means abiding by the restrictions on covered transfers and withdrawals that a customer may make. This chart, developed by Mary Beth Guard, helps you quickly determine which transfers and withdrawals are covered and which are not.
Reg D Transfer/Withdrawal Letter Guidance
Transfer/Withdrawal Restrictions Guidance from the FRB -- covers home banking, Internet banking, online bill pay issues.
Reg O Compliance
Reg O in a Box (html version) - handy guide to personalize for Reg O compliance within your institution from Pam Zyblut
(Word version of Reg O in a Box)
Reg O Flow Chart (revised 12/24) - from Jim Bedsole
Reg O Related Interest Worksheet - from Dave Majkowsk at Farmers-Merchants Bank and Trust. This is a Word document allowing you to customize it for your needs and circulate it so that you may annually update the insider's related interests, or request the information from a new insider. The first page contains the definitions so users will understand the meaning of what you need back. I suggest you include a copy of the prior years report to help guide them. Thanks Dave, for a great template on an always sensitive topic. (You may right click on the link and save the file to your hard drive.)
Reg Z Finance Charges Spreadsheet
This Regulation Z finance charges spreadsheet, submitted by KatH, organizes the fees charged by name, description, range, citation in the regulation, where it should appear on the HUD and TIL's, and much more. Take this spreadsheet and "tweak" it for your institution.
Risk Assessment Matrix
(right click on link and save the file to your hard drive)
Sample Advertising Policy and Procedures:
This sample advertising policy and procedure was generously made available to all BOL users from Marie Herrington, as an aid in reviewing a bank’s marketing and advertising initiatives for regulatory compliance.
Statistical Sampling Selection Tool
When completing an audit you need to know that the sample of records reviewed was statistically sound. This Audit Sampler allows a 90% reliability rate. You enter in only the total number of records that are subject to the audit and you'll see:
- The Sample Size - number of records needed
- The first record to select
- The interval of records necessary to reach the sample size.
Download the file here:
Website Checklist (html)
Website Checklist (doc file - right click on link and save the file to your hard drive)
Web Page Compliance Review Form
Debra A. Wetzel, MBA, CIA, CRCM, CRP, with National Penn Bancshares, Inc. (A $2.7 Billion Holding Company for National Penn Bank, Panasia Bank, N.A., Investors Trust Company, Penn Securities, Inc. and Penn 1st Financial Services, Inc.) has created a form for use in monitoring Web page compliance issues By law/regulation. This detailed worksheet covers requirements ranging from Reg E to RESPA. Debra welcomes input and feedback on it.