We're probably due for a compliance exam late this year or early next year. Has anyone had an exam recently? What are examiners looking at? What types of exceptions were they noting?

Any insight is appreciated!

We just had an OTS Compliance/Safety and Soundness Exam as well as an Information Technology exam. The compliance examiners looked at BSA. I believe they used the expanded exam procedures. They spent time on the travel rule. Make sure the proper data is going out with any wire transfers that are not exempt from the rule. They looked at Reg. E and our overdraft protection program. They reviewed the Internal Audit department's workpapers. IA had done a fair lending review so OTS reviewed that. They looked at flood insurance. They tested Reg. Z (TILs and ARM adjustments). They wanted to see open end credit periodic statements to ensure that we complied with the 7/1/10 Reg. Z changes. They tested HMDA. They only looked at two files under the new RESPA rule. They asked about the Servicemembers Civil Relief Act notice. They wante to see the HUD homeownership counseling notice. They inquired whether we made any loans subject to the military service members protections under John Warner National Defense Authorization Act. They also visited a branch to review signage. They wanted to see the FDIC TAGP notice.

The safety and soundness examiners reviewed Reg. GG.

They hammered fair lending... they looked at D, E, CC, DD like never before, scrutinized advertising and disclosures, NOW trials, Flood of course (WI is one of the worst offending states), loans with credit life, loans with PMI (current, paid off, requested dropped, auto dropped).

Got the heads up too that going forward, that the accuracy of the HMDA LAR data is back on their radar as well.

Make sure your HMDA data for the last two years is in good shape. Review all of your disclosures for compliance. Also, check your website for any compliance issues. Make sure you are crediting payments properly and according to the new Reg Z rules. Be prepared for a long discussion about ODP.

I'll second the website compliance issue and disclosures, especially with regards to Privay Policy, ODP, FDIC Insurance, TAGP and fees. We added verbiage to our fee schedule that 'this fee applies to insufficient funds [or to overdrafts] created by check, in-person withdrawal, ATM withdrawal or other electronic means' on the fees for insufficient funds debit returned unpaid and on the fees for each Debit Paid that Creates an Overdraft.

FDIC - October of last year.
**All of the above
**Vendor Management. FIL-44-2008 (Third-Party Risk)
**Regulation B - Spousal Signatures - Joint Intent