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#414179 - 08/25/05 09:12 PM Compliance reviews by product, not Reg
ML Offline
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Joined: Apr 2004
Posts: 220
I attended a BOL Webinar yesterday on "Residential Real Estate Loans: Performing a Compliance Audit." Patricia Cashman was the presenter and she mentioned that she prefers to audit by product and not reg. I think it sounds like a great idea and would save time jumping from here to there. My question is, does anyone else audit/review by product? If so, would anyone be willing to share what their audit/review schedule would like like for the year?

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#414180 - 08/26/05 02:57 PM Re: Compliance reviews by product, not Reg
DeeQ Offline
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DeeQ
Joined: Dec 2002
Posts: 40,760
Turnpike Exit 10
If you look at ABA's audit manual, it has comprehensive reviews by product rather than reg.

While I am still learning and trying to understand the subtleties (read: confusing language), I do them by the reg.
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#414181 - 08/26/05 03:38 PM Re: Compliance reviews by product, not Reg
ML Offline
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Joined: Apr 2004
Posts: 220
Thanks for the information. I'll check out their site.

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#414182 - 08/26/05 03:54 PM Re: Compliance reviews by product, not Reg
Starter Offline
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Starter
Joined: Aug 2004
Posts: 513
NJ
I do most by product (and when I say product, I mean also, "department' or "function"). I do still do some by reg such as BSA, Privacy, Reg O, etc.; but mostly by product.

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#414183 - 08/26/05 04:12 PM Re: Compliance reviews by product, not Reg
Anonymous
Unregistered

I go by reg except for loan compliance. I review btwn 30 and 50% of new loans and look at everything from TIL to underwriting.

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#414184 - 08/26/05 04:29 PM Re: Compliance reviews by product, not Reg
EdOils Offline
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EdOils
Joined: Jan 2004
Posts: 553
Louisiana
I'm not the auditor anymore, but when I was, I did a mixture of both. As Starter said, some areas, such a lending, it is just easier to look at one file for everything(flood, RESPA, HMDA, Reg Z, etc) then to just audit for one reg. Some areas, such as BSA, it just fits to audit just for that reg. Either way, you will probably notice things that you aren't auditing for that you may want to persue or put off til the next audit. Either way, don't limit yourself to just the areas that you are auditing. Keep your eyes and ears open.
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#414185 - 08/26/05 04:38 PM Re: Compliance reviews by product, not Reg
CalifDreamin Offline
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CalifDreamin
Joined: Mar 2002
Posts: 2,204
Far from Calif
I, too, prefer to do most by product rather than regulation, at least on the loan side. Otherwise, you can end up touching the same files many times. Here's my preference:

  • Consumer Loans
  • Residential Loans
  • Commercial Loans
  • CRA/HMDA (although parts of these are included on the other loan reviews as well)
  • BSA (this is one I may start splitting up, but not sure yet)
  • Reg E
  • Reg DD
  • Reg D/Q
  • Reg CC
  • Privacy
  • NDIP


This is just my general schedule, and it is subject to change annually depending on the "hot topics" for the year in case there's any special area I need to spend more time on. And, I don't review every part of each area/reg. every year unless I need to because there's just enough time in the year. For example, I only review the entire policy and procedure and forms for Reg. E if I am new to a bank, if a regulatory change has taken place, if a process/pol./proc. has changed, if it hasn't been reviewed in a couple of years, etc. Otherwise, the review will most likely focus on the higher risk area like Error Resolution.

Hope that helps.
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#414186 - 08/26/05 05:47 PM Re: Compliance reviews by product, not Reg
ML Offline
100 Club
Joined: Apr 2004
Posts: 220
I like the idea of mixing the audits. Some by reg some by product. It makes sense to audit lending by product. Thanks to all of you for your input. I always know I can count on getting great information from BOL users.
Thanks again.

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