It’s hard to believe that we are almost halfway through 2021. Many clients who have not been examined during the pandemic are asking for a “temperature” on the regulators.
Here are some of our insights about the compliance examinations over the past year that may help you to focus your efforts in preparation for future examinations:
Compliance Risk Assessment. The regulators have been taking a harder look at the Institution’s compliance risk assessment. In the past, a cursory review was done. This cycle we are seeing a focus on the inclusion of historical information and trending, clear delineation of inherent and residual risk and the inclusion of quantitative data to support risk factors and ratings.
TRID-RESPA Integrated Disclosures. It appears that the regulators have finally started to focus on the TRID-RESPA disclosures that Institutions have been grappling with for years. The focus appears to be very granular. We recommend that there be a second review process in place prior to the issuance of an LE or CD to ensure compliance. Ensure that you are properly…