Send Out Revised Hold Notices?

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Question:

During our compliance audit we noticed that periodically hold notices are being provided to customers for exception holds that have both exception and case by case checked. Do we need to have our staff send out revised forms that have only the exception hold box checked?

Answer:

I wouldn't. First, if you send out a revised notice, this could be confusing to the customer. Second, it doesn't correct the error that was already completed.

For most "information" errors (not computational), I suggest you do the following (this is from the Compliance Management webinar I teach). You can find it here.

Acknowledge the error and document it.No one is going to believe you have a very good audit program if you never find anything. Don’t cover up your mistakes. Compliance management is not about not having errors. It’s about finding them and what you do when you find them. The regulators want to know what you do when you find a problem.
Report the findings to the Board, Senior Management and/or Audit Committee on a regular basis.
Correct them if they are correctable.
1. Computational errors (APR, Finance Charges, payments, escrows) can and must be corrected.
2. Informational errors (disclosures) cannot be corrected. "Let the sleeping dog lie."
3. Flood insurance errors generally must be fixed (SFHDF, Notice, Inadequate or No Insurance).
Provide training on the weaknesses found.
Move on. Provide training and change your practices but don't dwell on the error. There's nothing you can do about it now.

First published on BankersOnline.com 1/28/08