Adverse Consequences from Late Adverse Action Notices
By John M. Floyd
Question: We have just discovered that one of our loan officers has
turn down applications on his desk since January 2003, what would be the proper way to handle this, is there any additional information that should be included in the letter since it is past the 30 day period to send out the letter. I think he has around 7 applications, is there anyway not to have a violation from the auditors.
Answer: We recommend that you send the adverse action notice immediately with a cover letter offering the opportunity to reapply if circumstances have changed. You will most likely be written up in your next compliance exam for hopefully an isolated violation. The examiners will probably review all subsequent adverse action notices to be sure you have corrected the problem. Immediately, you need to check and monitor that all notices have been and are going out on a timely basis.
JMF Boilerplate
John M. Floyd & Associates (JMFA) is a leading vendor of overdraft privilege programs serving more than 2,000 financial institutions in 49 states and Central America. JMFA is also nationally recognized for training, account acquisition and earnings enhancement programs, as well as product, service, pricing and technology improvement consulting. To learn more about John M. Floyd and Associates and to receive a FREE Overdraft Privilege Analysis, please visit www.JMFA.com or call 800-809-2307.
BankersOnline is a free service made possible by the generous support of our advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all banking professionals. Support our advertisers and sponsors by clicking through to learn more about their products and services.
Print Friendly!
Email This Article!
Discuss NOW!
