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#976518 - 06/17/08 04:46 PM Following bank procedures
Bville Offline
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Bville
Joined: May 2001
Posts: 1,282
Out West
In general, how do federal examiners react when they discover we aren't following our internal procedures, but are not necessarily violating the law?

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Lending Compliance
#976527 - 06/17/08 04:52 PM Re: Following bank procedures Bville
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
Depending on what it involves will be the basis for thier reaction.
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#976535 - 06/17/08 05:00 PM Re: Following bank procedures rlcarey
Rocky P Offline
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Joined: Jun 2003
Posts: 7,658
Florida
That situation is generally uncovered by internal or external auditors, and like Randy mentioned the regulator's reaction will be based on what is/is not being done.

The examiners will review the audit reports ane management responses. Sometimes, if there are mitigating circumstances or compensating controls, there will not be an issue other than why doesn't the bank re-write the procedures.
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#976572 - 06/17/08 06:02 PM Re: Following bank procedures Rocky P
Bville Offline
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Bville
Joined: May 2001
Posts: 1,282
Out West
I'm thinking of things like bank procedure requiring a written application for all consumer purpose loans or requiring customer signatures on RESPA and TIL disclosures that are not required by regulation. What if it tends to be certain branches or lenders that consistently do not follow bank procedure?

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