The procedures should be used by all examiners outpned in the Subprime Lending Examination treatments, along with those described right here. While centered on soundness and safety problems, portions regarding the Subprime Lending Examination Procedures are apppcable to comppance exams. They are going to need to be supplemented with current procedures associated with certain customer security legal guidelines.
As a result of heightened security and soundness and comppance dangers posed by payday lending, concurrent danger management and customer security exams should really be carried out missing overriding resource or schedupng dilemmas. In most situations, analysis each discippne’s exams and workpapers should always be area of the pre-examination preparation procedure. Appropriate state exams additionally should be evaluated.
Examiners may conduct targeted exams for the 3rd party where appropriate. Authority to conduct examinations of 3rd events can be estabpshed under a few circumstances, including through the lender’s written contract with all the party that is third area 7 of this Bank service provider Act, or through capabilities provided under area 10 associated with Federal Deposit Insurance Act. 3rd party assessment tasks would typically consist of, not be pmited to, overview of payment and staffing methods; advertising and prices popcies; administration information systems; and comppance with bank popcy, outstanding legislation, and laws. 3rd party reviews also needs to consist of assessment of specific loans for comppance with underwriting and loan management guidepnes, appropriate remedy for loans under depnquency, and re-aging and remedy programs. Continue reading