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#1596244 - 08/25/11 12:41 PM OCC Foreclosure Management Guidance
Sugarbaker Offline
Gold Star
Joined: Nov 2005
Posts: 265
Does anyone have any type of checklist to use to complete the self-assessment on foreclosure management that the OCC is requiring to be done by Sept.30?

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Lending Compliance
#1596484 - 08/25/11 03:56 PM Re: OCC Foreclosure Management Guidance Sugarbaker
Hondo&Harley Offline
New Poster
Joined: Apr 2002
Posts: 3
I picked these risks out of the Interagency Review:

Foreclosure Process Governance
Inadequate policies, procedures and independent controls
Lack of sufficient audit trail to link internal records to information set out in affidavits.
Inadequate identification of financial, reputational and legal risks and absence of internal communication about risks to board and senior mgmt.

Organizational structure and availability of staffing
Inadequate organization and staffing of foreclosure units to address the increased volumes of foreclosures.

Affidavit and notarization practices
Individuals signing documents lack level of knowledge attested to in affidavits.
Improper notary requirements that fail to conform to state requirements.

Documentation practices
Errors between actual fees charged and what internal records indicate.

Third party vendor management
Inadequate monitoring of foreclosure activities conducted by external law firms.
Lack of physical control of original documents.
Notes not properly endorsed or DOTs properly assigned.
Third party default management service providers have been found deficient .
The Mortgage Electronic Registration Systems Inc. has significant weaknesses

QC and audit
Inadequate QC and audits to ensure compliance with legal requirements.
Inadequate controls to prevent foreclosures when intervening events occur that warrant stopping the foreclosure process.

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