June 13, 2012
12:00 pm - 1:30 pm PT
1:00 pm - 2:30 pm MT
2:00 pm - 3:30 pm CT
3:00 pm - 4:30 pm ET
Meet the Presenter
Ann Brode, Brode Consulting Services, Inc.
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Loan denials are receiving increased scrutiny during recent examinations to ensure that adverse action notices are complete and accurate, documentation is impeccable, and there are no fair lending concerns/violations. How will your procedures fare under intensified examination? This session will address the technical requirements of denials for consumer, residential, and commercial loans.
Accurate completion of adverse action notices is important for several reasons:
- Their accuracy and timeliness are reviewed during compliance exams
- Adverse action notices are the cornerstone of fair lending examinations
- Inconsistent, inaccurate notices could result in the credit union being required to go back six months, review past notices, and resend accurate denial notices. (Imagine the reaction of a past, unsuccessful borrower who receives a reminder denial notice!)
This webinar will provide examples of examiner findings to illustrate what is covered during exams and show you how to include denials in the sample for your internal comparative file review for fair lending compliance.
- Timing requirements of Regulation B for denials
- Inquiry versus Application (when an inquiry becomes an application)
- Special considerations for commercial denials
- FACT Act requirements for denial notices
- Common errors in completing adverse action notices
- Requirements for incomplete and withdrawn applications
- How to appropriately document withdrawn applications
- Handling counteroffers
- Second reviews of adverse action notices for fair lending purposes
- Comparative file review for fair lending on denials
WHO SHOULD ATTEND?
This informative session is necessary for all loan officers, loan processors responsible for denials, compliance officers, and auditors.