Loan Compliance Program

Posted By: compliancemom

Loan Compliance Program - 03/13/09 01:56 PM

Please help! I've taken on the responsibility of overseeing loan compliance for our 200m bank and need some advice in enhancing the current program. My expertise is BSA, but i do have previous loan audit experience (compliance side). The following is what I've gleaned from reading the FDIC exam handbook and other resources. I'd like some feedback on areas I may be missing:

1. Loan policies/procedures (already in place)
2. Loan audit ?? How frequently should we do these? Right now someone is looking at every single loan though no formal audit write-ups are being done.
3. Training - yearly, monthly or as needed?

Anything else?
Posted By: renniks

Re: Loan Compliance Program - 03/13/09 02:05 PM

My advice is to make sure that HMDA and Flood Policies and Procedures are in place and are being followed. Those two issues seem to be the most common cause of MOU's and CMP's.
Posted By: Andy_Z

Re: Loan Compliance Program - 03/13/09 09:34 PM

Review the last two exams, internal and external, to see what was noted as problems and ensure they were or are being fixed.

Look at our Top Stories page, it is linked to above in the link bar, and when at that page, in the upper right you'll see regulatory changes. You have to prepare for them. LOTS and lots of changes are coming in Lending.

Some of your questions need more info. Are there loan problems cited now? How often are they audited? What is the volume? You should see what I am getting at. Where does this fall on your current risk analysis, it is high b/c there are problems, it is low b/c there are no problems or it isn't known. The same for training.
Posted By: Richard Insley

Re: Loan Compliance Program - 03/13/09 09:54 PM

If your bank is working on new products or reworking old ones, become part of the team. Design regulatory compliance into the marketing and delivery of your products and you can avoid lots of trouble later on. An ounce of prevention is worth a pound of audits, reports, and retraining.
Posted By: Bagweaver

Re: Loan Compliance Program - 03/16/09 12:03 PM

Document anything that is being reviewed even if it's just a matter of checking a box on a spread sheet. Examiners want to see what's being done. I ran into this in an exam years ago.
Posted By: compliancemom

Re: Loan Compliance Program - 03/17/09 04:19 PM

Thanks for the advice. The last loan exam and audit were good overall. An external auditor was used last year at the recommendation of examiners because there wasn't a chief compliance officer. Now that I'm here, we plan to keep it internal. We're doing a light review of new loans but need a more in-depth review periodically. I just wasn't sure how often.... No HMDA, small bank CRA, rural, low to mod risk....