Thread Options 
|
#384452 - 07/12/05 05:59 PM
What do you use to do Reg Z training?
|
Gold Star
Joined: Feb 2002
Posts: 461
Mississippi River Valley
|
I have been asked to come up with some Reg Z training for lending staff. Because of how big and complex Reg Z is, I am having a very difficult time nailing this down.
What do you use at your bank to do Reg Z training?
We already use an Internet based company for training on a wide range of regulations which includes 5 courses on Reg Z, but the OCC wants us to do more training. Any suggestions or direction given will be appreciated.
_________________________
How long a minute is depends on what side of the bathroom door you're on.
|
|
Return to Top
|
|
|
|
|
#384453 - 07/12/05 06:26 PM
Re: What do you use to do Reg Z training?
|
10K Club
Joined: Oct 2000
Posts: 10,180
Toano, VA
|
Reg. Z training can easily become a waste of time (and therefore damage the credibility of your whole training program.) Unlike Reg. B and other lending regs, lenders typically have systems in place that make most of Reg. Z a no-brainer.
Focus your training efforts on those systems and your procedures for using them. If you have classified all your fees (FC/non-FC), for example, the lenders don't need to understand what's a FC, just what your procedures and systems require.
This narrows your training task down to ROR, delivery timing for various disclosures, and anything that is transaction-specific.
_________________________
...gone fishing.
|
|
Return to Top
|
|
|
|
|
#384454 - 07/12/05 08:04 PM
Re: What do you use to do Reg Z training?
|
Power Poster
Joined: Nov 2001
Posts: 7,985
FINALLY ABOVE the gnat line
|
Unfortunately, Richard, even tho we've defined it for them in the loan documentation software, LO's can always "invent a fee". I find it useful to cover the definitions periodically and provide examples of what is and what is not a FC. This isn't done every year - just when monitoring indicates that its a problem. What disclosures to provide when and under what circumstances also helps. Not to mention HOEPA.
_________________________
"Once you learn to read, you will be forever free."
- Frederick Douglass
My Opinion Only.
|
|
Return to Top
|
|
|
|
|
#384455 - 07/13/05 02:30 AM
Re: What do you use to do Reg Z training?
|
10K Club
Joined: Oct 2000
Posts: 10,180
Toano, VA
|
Why don't you adopt a policy that all fees are born as FCs. In order for the fee to be treated as anything else, its creator must convince you it's not a FC. Until a fee finds its way onto your approved list of non-FCs, the policy would instruct your servicing manager(s) to refund it automatically if it's not included in the FC.
_________________________
...gone fishing.
|
|
Return to Top
|
|
|
|
|
#384457 - 07/13/05 11:34 AM
Re: What do you use to do Reg Z training?
|
Anonymous
Unregistered
|
How about the same question but HMDA/GMI instead? How do you train loan officers on when NOT to ask the HMDA/GMI questions?
|
|
Return to Top
|
|
|
|
|
#384458 - 07/13/05 01:00 PM
Re: What do you use to do Reg Z training?
|
Power Poster
Joined: Nov 2001
Posts: 7,985
FINALLY ABOVE the gnat line
|
I like that idea!
_________________________
"Once you learn to read, you will be forever free."
- Frederick Douglass
My Opinion Only.
|
|
Return to Top
|
|
|
|
|
#384459 - 07/13/05 01:16 PM
Re: What do you use to do Reg Z training?
|
10K Club
Joined: Oct 2000
Posts: 10,180
Toano, VA
|
Although Bonnie thinks I'm being a bit harsh, at some point your fees have to be judged and you don't want an examiner to be the one doing it. (Reimbursement orders happen.) If your lenders get immediate feedback when their first bogus invent-a-fee is reimbursed automatically, the problem doesn't grow. Should you try to implement my policy, pitch it to the lenders as a way they can offload a regulatory duty to you and be excused from a long boring training session on Reg. Z. What's not to like about that!
_________________________
...gone fishing.
|
|
Return to Top
|
|
|
|
|
#384460 - 07/13/05 01:59 PM
Re: What do you use to do Reg Z training?
|
Gold Star
Joined: Feb 2002
Posts: 461
Mississippi River Valley
|
Thanks, Louvera, for the information. With some minor modifications it will work great! I always hate having to "reinvent the wheel" so thanks again for sharing your information!
Thanks also to Richard and Bonnie for your comments. I too like the "all fees are FCs unless proven otherwise" idea!
_________________________
How long a minute is depends on what side of the bathroom door you're on.
|
|
Return to Top
|
|
|
|
|
#384462 - 07/13/05 03:09 PM
Re: What do you use to do Reg Z training?
|
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
|
Quote:
Reg. Z training can easily become a waste of time (and therefore damage the credibility of your whole training program.) Unlike Reg. B and other lending regs, lenders typically have systems in place that make most of Reg. Z a no-brainer.
Focus your training efforts on those systems and your procedures for using them. If you have classified all your fees (FC/non-FC), for example, the lenders don't need to understand what's a FC, just what your procedures and systems require.
This narrows your training task down to ROR, delivery timing for various disclosures, and anything that is transaction-specific.
For what its worth, I totally agree with this concept. We don't conduct any Reg Z training per se, except for the obvious issues that are mentioned above. Reg Z is primarily incorporated into systems and software, which we test prior to implementation. In general, our lenders don't want to know all the "why" with Reg Z. They just want to know what fee to plug into what field so that the APR is correct. We don't leave options for creativity. That's not to say that there isn't an occasional renegade fee. But our Loan Operations Department is the stop gap for creative lenders. Exceptions are well monitored when the loan documents hit that department. Then we have the immediate opportunity to take corrective action.
|
|
Return to Top
|
|
|
|
|
|
Previous Thread
Index